Department of Homeland Security 

Office of Inspector General 

The DHS Personnel Security Process
 

OIG-09-65 May 2009 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

 May 7, 2009 

Preface 

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

established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the strengths and weaknesses of the department’s personnel 

security program. It is based on interviews with employees and officials of relevant 

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

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all who contributed to the preparation of this report. 

Richard L. Skinner 


Inspector General 

Table of Contents 


Executive Summary.............................................................................................................1
 

Background..........................................................................................................................2
 

Overview of Personnel Security ....................................................................................2 


Mandated Requirements ................................................................................................8 


Results of Review ..............................................................................................................11
 

Consolidation of the Intake Process.............................................................................11 


Alignment of Personnel Security Policies ...................................................................17 


Coordination of Key Operations..................................................................................25 


Management Comments and OIG Analysis ......................................................................37 


Appendixes 

Appendix A: Purpose, Scope, and Methodology........................................................47 


Appendix B: Management Comments to the Draft Report ........................................48 


Appendix C: Background Investigations....................................................................74 


Appendix D: General Personnel Security Process......................................................75 


Appendix E: Component Specific Personnel Security Information ...........................77 


Appendix F: Major Contributors to This Report ........................................................86 


Appendix G: Report Distribution................................................................................87 

Table of Contents 


Acronyms and Abbreviations 

CBP Customs and Border Protection 

CFR Code of Federal Regulation 

CHCO Chief Human Capital Office 

OCSO Office of the Chief Security Officer 

DAE disaster assistance employee 

DHS Department of Homeland Security 

DNI Director of National Intelligence 

EOD entry-on-duty 

e-QIP electronic Questionnaire for Investigative Processing 

FBI Federal Bureau of Investigation 

FEMA Federal Emergency Management Agency 

FLETC Federal Law Enforcement Training Center 

FTE full-time equivalent 

HR human resources 

ICE Immigration and Customs Enforcement 

IRTPA Intelligence Reform and Terrorism Prevention Act of 2004 

ISMS Integrated Security Management System 

JRT Joint Reform Team 

MD Management Directive 

NAC National Agency Check 

NACI National Agency Check with Inquiries 

OIG Office of Inspector General 

OMB Office of Management and Budget 

OPM Office of Personnel Management 

PAC Performance Accountability Council 

PD position description 

PerSec Personnel Security Office 

PO Program Office 

PSD Personnel Security Division 

SECCEN United States Coast Guard Security Center 

TSA Transportation Security Administration 

USCG United States Coast Guard 

USCIS United States Citizenship and Immigration Services 

USSS United States Secret Service 
OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

This report assesses the effectiveness and efficiency of the 

Department of Homeland Security’s personnel security programs. 

At the creation of the Department of Homeland Security, the 

Office of Security was given oversight of component personnel 

security programs. In 2005, the Office of Security, Personnel 

Security Division, was instructed to develop departmental 

personnel security policies and procedures. Department of 

Homeland Security Management Directive 11080 requires 

components to collaborate, participate, and recognize the shared, 

related, and interdependent responsibility to provide effective and 

efficient personnel security services to the department. 

Department of Homeland Security personnel security offices are 

performing similar functions but use different policies throughout 

the personnel security process. Across the department, 

components strive to provide quality results in a timely manner but 

often are delayed by applicants, overwhelmed by customer service 

requests, restricted by database functions, and limited by 

information availability. The personnel security process is 

complicated. Application of reciprocity requires unification of 

Department of Homeland Security financial criteria, combination 

of temporary hiring requirements, and standardization of 

adjudication training. Further, department personnel security 

programs would benefit if better relationships could be established 

between the Office of Personnel Management and the Department 

of Homeland Security Chief Human Capital Office. The 

Department of Homeland Security personnel security program 

could be made more efficient and effective by consolidating the 

personnel security intake process, standardizing personnel security 

policies, and establishing better relationships. 

We are making 20 recommendations to improve the Department of 

Homeland Security’s personnel security process. 

The DHS Personnel Security Process 

Page 1 
 

Background 

Overview of Personnel Security 

All federal government positions require a risk and sensitivity designation. 

The highest level of risk or sensitivity determines the type of background 

investigation required. The greater the risk or sensitivity inherent in the 

position, the more extensive a background investigation is required. Once 

designations are made, the background investigation can be initiated and 

reviewed for suitability. With a favorable suitability determination, an 

applicant can be hired. Figure 1 illustrates the general personnel security 

process. 

Figure 1. The Personnel Security Process 

Source: OIG, derived from multiple sources. 

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Risk Designation 

Risk designation is based on an evaluation of the potential adverse 

effect that a position may have on an agency. As a result, position 

risk designation guides the personnel security process. Personnel 

security specialists closely review the position description (PD), a 

written statement of the major duties, responsibilities, and 

supervisory relationships of the position. Human resource (HR) 

offices designate the level of position risk as the low, moderate, or 

high. The risk level corresponds to the appropriate type of 

background investigation, as shown in Figure 2. 

Figure 2. Position Risk and Background Investigation 

Position Risk and Background Investigation 

Low Risk National Agency Check with Inquiries 

Moderate Risk Minimum Background Investigation 

High Risk Background Investigation 

Source: OIG, derived from multiple sources. 

Position Sensitivity 

As shown in Figure 3, position sensitivity determines whether 

access to classified information is required. Sensitivity is reviewed 

in addition to risk designation. There are two types of federal 

government positions: Public Trust and National Security. Public 

Trust positions may involve policy making, law enforcement 

duties, or control of financial records, or may demand a significant 

degree of public confidence in the employee.1

 National Security 

positions are those in which the employee needs access to 

classified national security information to perform the duties of the 

position.2 

1

 Title 5 Code of Federal Regulations 731.106(b). 

2

 Title 5 Code of Federal Regulations 732.102. 

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Figure 3. The Sensitivity Level Designation 

Sensitivity Level Designation 

NonSensitive No access to classified information 

Noncritical 

Sensitive 

Access to Secret or Confidential information and may 

adversely affect overall operations of DHS 

Critical 

Sensitive 

Access to Top Secret information; investigative duties, 

involvement with personnel security clearances or 

boards; or other national security positions that may 

adversely affect the overall operations of DHS and 

national security 

Special 

Sensitive 

Access to intelligence-related Sensitive Compartmented 

Information, the misuse of which may gravely affect 

overall DHS operations and national security 

Source: OIG, derived from multiple sources. 

The risk and sensitivity designation determines the type of 

background investigation required. The Office of Personnel 

Management (OPM) developed the minimum requirements for the 

scope of the investigations used to grant access to classified 

information.3

 At any time, if the initial background investigation 

has not been done at the required level, a new investigation will be 

required. With approval, an agency may do more than what is 

required for a basic background investigation on a position, but not 

less. 

Suitability 

Risk and sensitivity designations are specific to each position, not 

to an employee. In contrast, suitability is an evaluation of the 

fitness the character and trustworthiness of the individual for 

the position. Suitability adjudication considers only an 

individual’s personal conduct. OPM defines suitability as: 

Identifiable character traits and conduct sufficient to 

decide whether an individual is likely or not likely to be 

able to carry out the duties of a federal job with 

appropriate integrity, efficiency, and effectiveness.4 

The suitability determination is a process that subjects employees’ 

personal conduct to evaluation throughout their careers. Suitability 

is often confused with position qualifications. Qualification 

determinations are based on the individual’s experience, education, 

knowledge, skills, and abilities, while suitability involves an 

assessment of past and present conduct. The assessment is 

3 OPM Federal Investigative Notice Letter No. 97-02, July 29, 1997. 


4

 OPM Suitability Primer, 2007. www.archives.gov/isoo/oversight-groups/nisp/opm-suitability-primer.pdf. 


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intended to establish a reasonable expectation that the individual 

will protect the integrity or promote the efficiency of the agency. 

An initial suitability determination includes a preliminary check of 

credit, name, address, education, and fingerprints to establish 

whether the applicant can perform the duties without 

compromising national security or public trust. If an individual 

successfully clears preliminary checks, the applicant is eligible for 

an interim security clearance. Interim clearances can be granted 

pending the completion of the full background investigation and 

adjudication for the final clearance. If unfavorable information is 

identified on the application form or during the background 

investigation, the interim clearance may not be issued or can be 

revoked. In some agencies, applicants are reviewed multiple times 

during their probationary period. The full adjudication process 

examines a sufficient period of a person’s life to affirm that the 

individual is an acceptable risk. Each agency, after reviewing all 

available information, determines the degree of acceptable risk and 

judges each case on its own merits. Final determinations remain 

the responsibility of the hiring agency. 

The suitability determination recognizes that there may be adverse 

elements in an individual’s past conduct that would not be relevant 

to the federal position to which the individual is applying. 

Incidents of previous bad conduct, such as driving while 

intoxicated, possessing or using marijuana, or experiencing 

indebtedness, do not automatically disqualify an applicant for 

federal employment. These types of incidents may be assessed to 

determine whether they are sufficient in nature and gravity to result 

in an unsuitable determination for federal employment in a 

particular position. In fact, even individuals with a criminal 

conviction can be hired as long as they meet the specific suitability 

requirements for the particular position. For example, an applicant 

convicted of battery could be deemed suitable for a clerical 

position. However, the same applicant might be unsuitable for a 

law enforcement position that requires the employee to carry a 

firearm. Adjudicators carefully analyze factors that may mitigate 

the conduct. The nexus between the conduct and the position is 

the determinant. 

Title 5, Code of Federal Regulation (CFR) Part 731, established 

factors that are used to make a determination of suitability. Part 

732 set forth requirements to determine national security positions. 

Issues discovered during a background investigation are the basis 

for disqualification. Adjudicators consider types of conduct that 

could be incompatible with the core duties of a position. The 10 

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types of conduct issues shown in Figure 4 can be used to screen 

candidates.5 

Figure 4. Type of Conduct Issues 

Type of Conduct Issues 

Intoxicants 

Drug use 

Financial irresponsibility 

Criminal and immoral conduct 

Dishonesty 

Disruptive or violent behavior 

Employment misconduct, negligence 

Firearms and weapons violations 

Statutory debarment 

Miscellaneous agency-specific requirements 

Source: OPM Suitability Referral Chart. 

Each issue identified by an adjudicator is assigned a grade between 

A and D based on seriousness, as shown in Figure 5. Any gradable 

issue may be considered a basis for determining an individual 

unsuitable. 

Figure 5. Seriousness of Issues 

Issue 

Level Seriousness Issue Description 

A Minor 

Conduct or issue, standing alone, 

would not be disqualifying under 

suitability for any position 

B Moderate 

Conduct or issue, standing alone, 

would probably not be disqualifying 

under suitability for any position 

C Substantial 

Conduct or issue, standing alone, 

may probably be disqualifying under 

suitability for any position 

D Major 

Conduct or issue, standing alone, 

would be disqualifying under 

suitability for any position 

Source: OPM; U.S. Department of Agriculture Graduate School, Suitability 

Adjudication, Version 2.1. 

Suitability determinations are reevaluated periodically. This 

process is especially important for individuals who have been 

issued security clearances at the Secret or Top Secret level, as the 

investigation determines their trustworthiness for continued access 

to classified information. An updated Standard Form 86 must be 

completed for the adjudication process. If adverse information, 

5

 Some DHS components have additional congressional mandated requirements that must also be 

considered. 

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such as excessive bad debt, is discovered in the reevaluation, the 

adjudicator can make an unfavorable suitability determination. 

Continuous reevaluation of individuals employed by the federal 

government ensures that only the most qualified and trustworthy 

individuals remain employed. 

Security Clearance 

A security clearance is a determination that a person can access 

classified information.6

 The decision to grant a security clearance 

can be made after the final suitability determination. Security 

clearance determinations are based on the information from 

preliminary checks, gathered from the background investigation, 

and evaluated by an adjudicator.7

 Figure 6 lists the three security 

clearance levels. 

Figure 6. Security Clearance Levels 

Level Access to Information Reinvestigated 

Confidential 

Information that reasonably 

could be expected to cause 

damage to the national 

security if disclosed to 

unauthorized sources 

Reinvestigation 

conducted every 

15 years 

Secret 

Information that reasonably 

could be expected to cause 

serious damage to the 

national security if disclosed 

to unauthorized sources 

Reinvestigation 

conducted every 

10 years8 

Top Secret 

Information that reasonably 

could be expected to cause 

exceptionally grave damage 

to the national security if 

disclosed to unauthorized 

sources 

Reinvestigation 

conducted every 

5 years 

Source: OIG, derived from multiple sources. 

Employees do not own their security clearance. A security 

clearance is a privilege granted by the federal government, and it 

can be revoked at any time if unfavorable information about the 

employee is discovered. Employees who remain employed but no 

longer require access to classified information can have their 

clearances administratively downgraded or withdrawn. If 

classified access is required again, the clearance can be reissued 

6

 Executive Order 12598, Classified National Security Information, April 17, 1995; OPM Federal 


Investigative Notice Letter No. 97-02, July 29, 1997. 
 7

 Security clearance eligibility is based on information related to foreign influence, foreign preference, 


sexual behavior, psychological conditions, or other outside activities. 
 8

 These requirements may change based on work being conducted at the federal level by the Joint Security 


and Suitability Reform Team.
 

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provided the background investigation has not expired. Agency 

clearances are terminated when an employee permanently leaves 

the agency; however, the new agency may use the background 

investigation already performed by the former agency to issue a 

security clearance. 

Reciprocity 

Reciprocity occurs when an agency accepts a security clearance 

granted to an individual by a former agency.9 The concept of 

security clearance reciprocity has existed for decades. However, 

because agencies have specific missions, reciprocity can be 

difficult to achieve. Reciprocity is especially complicated for 

defense, intelligence, and law enforcement agencies. 

Mandated Requirements 

Personnel security programs were established in 1953 by Executive 

Order 10450 and enhanced in 1995 by Executive Order 12968. These 

orders set the standards for suitability and security clearance processes for 

the federal government, and the processes were reformed in 2008 by 

Executive Order 13467. In addition, Title 5 CFR Part 731 and Part 732, as 

amended, define specific suitability factors that must be considered when 

adjudicating applicants. The Intelligence Reform and Terrorism 

Prevention Act of 2004 (IRTPA) sets goals and timelines for granting 

clearances, ensuring reciprocity, and establishing an integrated database 

for completed background investigations.10 DHS has also developed 

management directives to implement federal requirements across the 

department. 

Executive Orders Governing Personnel Security 

Executive Order 10450 required agency heads to establish effective 

security programs and set minimum background investigation 

requirements for federal employment based on risk designation. 

Executive Order 12958 ensured that certain information related to national 

interest is maintained through a classification system. Executive 

9

 OMB Memorandum, Reciprocal Recognition of Existing Personnel Security Clearances, December 12, 


2005. 


10 Public Law 108-458. 


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Order 13467 reformed the use of reciprocity across the government to 

ensure cost-effective, timely, and efficient protection of national interests. 

Exceptions to the reciprocity standard are allowed for certain highly 

sensitive programs. 

United States Code of Federal Regulations 

OPM has oversight of federal personnel security programs, including 

background investigation programs. Its authority is delegated primarily 

through regulations contained in Title 5 CFR Part 731, “Suitability,” and 

Part 732, as amended, “National Security Positions.” Part 731 established 

the process and procedures for determining suitability eligibility for 

federal employment, and Part 732 established both the requirements for 

national security positions and the criteria for adjudicating them. 

The Intelligence Reform and Terrorism Prevention Act of 2004 

Following the events of September 11, 2001, Congress criticized the 

amount of time it took to hire federal employees. IRTPA contained 

specific processing deadlines for completing the personnel security 

investigation and adjudicatory phases. OPM was designated the central 

depository for all federal government background investigations and 

adjudications. OPM developed the electronic Questionnaires for 

Investigations Processing (e-QIP) to manage applicant personnel security 

information across the federal government. 

e-QIP allows federal job applicants to electronically enter, update, and 

transmit their personal investigative data to the hiring agency. Applicants 

complete personnel security forms, including the Standard Forms 85 

Questionnaire for Non-Sensitive Positions, 85P Questionnaire for Public 

Trust Positions, and 86 Questionnaire for National Security Positions, 

through e-QIP. Figure 7 describes IRTPA processing requirements. 

Figure 7. The 2004 IRTPA Processing Requirements 

Phase December 2006 December 2009 

Investigation 

Completed 90 days 40 days 

Adjudication 

Completed 30 days 20 days 

Total 120 days on 80% of all 

applications 

60 days on 90% of all 

applications 

Source: OIG, derived from IRTPA. 

Since the implementation of IRTPA, OPM has made two other 

improvements to background investigation processes: the Clearance 

Verification System, which shares clearance records among agencies, and 

Imaging, an electronic document project to reduce paper use. With e-QIP, 

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the three new programs comprise OPM’s “e-Clearance initiative.” As of 

March 2007, all federal government agencies had signed agreements with 

OPM to use e-QIP for national security clearance investigation requests. 

Department of Homeland Security Management Directives 

On June 30, 2008, DHS Management Directive (MD) 121-01 assigned 

authority for DHS security programs to the Office of the Chief Security 

Officer (OCSO). The directive requires the OCSO to oversee DHS 

personnel security policies, programs, and standards; deliver security 

training and education to DHS; and provide personnel security support to 

DHS components. The directive also established a CSO Council 

responsible for the development of a departmental security strategic plan, 

establishment of priorities for the security program, and integration of 

department-wide security programs. 

MD 11050.2 set DHS procedures for designating sensitivity, investigative 

standards for security clearances, and suitability determinations. The 

directive defined minimum standards, but did not prohibit additional 

requirements based on mission criticality. The directive made the DHS 

OCSO responsible for ensuring the issuance, implementation, and 

compliance of written policies. 

MD 11080 required that component heads support and collaborate with 

the OCSO. The directive set three procedural guidelines for DHS’ 

security functional integration: 

1.	 Standardization of security policies and appropriate procedures; 

2.	 Continued consolidation and integration of systems supporting 

DHS’ security functions; and 

3.	 Consolidation of organizations that perform the same function.11 

The DHS Personnel Security Division (PSD) has drafted an Instruction 

Handbook on Personnel Suitability and Security Program. The 

publication establishes procedures, program responsibilities, minimum 

standards, and reporting protocols for the department personnel security 

programs. The instruction also provides information on personnel security 

authorities and responsibilities, requirements for background 

investigations, and adjudications. 

11 DHS Management Directive Number 11080. 

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Results of Review 

All full-time DHS employees receive a background investigation and 

adjudication. Approximately 70,000 of the 208,000 DHS employees occupy 

positions requiring access to classified information. Some components are 

responsible for conducting their agency’s personnel security functions, but must 

report to the OCSO. Many components have developed similar processes for 

initiating the personnel security process, resulting in duplicative efforts 

throughout the department. The key difference occurs in the application of 

mission-specific suitability standards during adjudication. A number of personnel 

security processes throughout DHS could be combined to create a more efficient 

and effective process. DHS PSD, as part of the OCSO, has the authority to make 

significant changes to the personnel security process across the department. The 

establishment of a consolidated DHS personnel security intake process would 

align personnel security policies and better coordinate key DHS operations. 

Consolidation of the Intake Process 

Across DHS, individuals selected for positions are required to complete eQIP. The e-QIP form has consent pages that require the applicant’s 

signature. The pages must be mailed to the agency upon completion of eQIP. Preliminary checks can be conducted once the hiring agency 

receives notification that e-QIP has been completed and receives all 

documentation. 

Preliminary checks are the initial verifications done by an agency to 

determine whether an applicant meets the minimum hiring requirements. 

The agency may also conduct other checks if it has the capabilities. If not, 

the agency can request additional checks when submitting a National 

Agency Check with Inquiries (NACI) request to OPM. The NACI is a 

search of investigative files and other records held by federal agencies. 

The selectee’s fingerprints are electronically submitted to the Federal 

Bureau of Investigation (FBI) for a criminal record check. Components 

can use the OPM FBI fingerprint check inquiry option, but most submit 

the fingerprint card directly to the FBI.12 For applicants who have prior 

federal service and have had a background investigation conducted in the 

past 5 years, and whose break in service has not exceeded 2 years, the 

hiring agency will request the previous investigation. In most 

components, an interim clearance and entry-on-duty (EOD) date can be 

issued once a selectee has passed the preliminary checks. The component 

must be satisfied with results from the preliminary checks since the 

selectee’s background investigation has not yet been fully vetted against 

the agency suitability standards. Figure 8 illustrates the preliminary 

checks process. 

12 Requests without an OPM FBI fingerprint inquiry are called National Agency Checks (NAC). 

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Figure 8. The Preliminary Checks Process 

6. Preliminary 	 1. Selected 

checks individual 

complete. completes 

e-QIP. 

5. Agency 

requests 2. Signature and 

previous fingerprints 

background received by 

investigation. agency. 

4. Fingerprints 3. NACI request 

submitted to submitted to 

FBI. OPM. 

Source: OIG, derived from multiple sources. 

Role of the Selectee 

DHS personnel security offices agreed that the most timeconsuming part of the initiation process involved the selectee. The 

selectee’s responsiveness dictates when the security process can 

proceed. Some selectees respond immediately, but components 

noted that others have taken several weeks to respond or fail to 

respond at all. The average response time for selectees who do 

submit their forms in e-QIP is 10 days. 

Some components have developed mitigating strategies to offset 

delays caused by the selectee. For example, in one component the 

hiring program manager is notified if the selectee has not 

completed e-QIP in 10 days. By keeping the program manager 

involved, the hiring agency can withdraw the tentative 

employment offer if the selectee does not complete e-QIP in a 

timely manner. In another component, the hiring process is 

discontinued if e-QIP is not completed within 30 days. Offices 

that have developed these types of selectee response strategies 

have reduced hiring delays. 

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We recommend that the Under Secretary for Management: 

Recommendation #1: Establish a department wide requirement 

for selectees to complete e-QIP within a specified number of days, 

and develop strategies to manage selectees who do not meet the 

response requirement. 

Customer Service 

According to component officials, many selectees have difficulty 

accessing e-QIP or have questions regarding the online system. 

System access problems can result from technical or user issues. 

Six of the nine components included in our review have created a 

customer service group to address selectee questions. Some 

components have an 800 number, while others use an e-mail 

system to address customer service questions. e-QIP customer 

service groups answer questions daily about forgotten passwords 

or failed system access. e-QIP problems are not unique to 

applicants. Often HR offices have issues with e-QIP and cannot 

access the system. 

United States Immigration and Customs Enforcement (ICE) has a 

customer service desk and intake unit responsible for handling 

customer questions, addressing e-QIP issues, filing, and managing 

training. In June 2008, the ICE intake unit responded to 

1,268 phone calls, 2,024 e-mail messages, and 238 walk-in 

inquiries pertaining to the personnel security process. In the same 

month, the intake unit received 748 new cases requiring 

preliminary checks. The Transportation Security Administration 

(TSA) uses four units Customer Service, e-QIP Customer 

Service, Customer Review, and Scanning and Scheduling to 

handle internal and external customer questions on status updates 

or e-QIP, manage filing, and schedule investigations. TSA 

officials estimated that their customer service office receives more 

than 200 requests each day through e-mail, telephone, and fax. 

The United States Citizenship and Immigration Services (USCIS) 

answers all incoming inquiries via e-mail or phone. Inquiries are 

generally from program managers and selectees on the status of 

applications. In July 2008, USCIS received 252 calls regarding eQIP, 107 regarding the security process, and 64 regarding 

applicants who were not selected. 

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We recommend that the Under Secretary for Management: 

Recommendation #2: Delegate all customer service 

responsibilities to the DHS Personnel Security Division. 

Preliminary Checks 

Each component we reviewed has an internal division dedicated to 

processing and collecting selectee information to initiate the 

preliminary checks. Components with the highest volume of 

incoming cases were forced to develop intake groups or be 

overwhelmed. Only three components could determine the 

number of days it took to process intake functions. Some 

component officials said their components would benefit from an 

intake function; however, their organizations do not have the staff 

or funding to support an intake operation. Personnel security staffs 

with specialized adjudicator training are instead being used to 

perform basic clerical tasks such as filing documents, answering 

phones, and compiling selectee information. 

Some components use a standardized intake process. DHS PSD 

recently reorganized its process to include a centralized intake 

function. The intake function was designed to initiate e-QIP, 

process forms, and conduct preliminary checks. ICE also aligned 

current staffing resources to form a standardized intake process. 

Many personnel security specialists noted that the standardized 

intake process reduced the time that was previously used to 

complete administrative tasks. Of all the personnel security offices 

we examined, ICE is uniquely structured to accomplish the IRTPA 

requirements. 

According to DHS personnel security officials, implementing a 

consolidated intake function would require significant funding 

shifts. However, a centralized department-level personnel security 

intake processing center could also provide DHS PSD with a way 

to monitor customer service and intake issues across the 

department. This function could handle all e-QIP issues and 

initiate preliminary background checks (fingerprint submission, 

credit check, citizenship verification, employment, residency, and 

Selective Service checks). It could request previous investigative 

files from other agencies when appropriate. It would provide a 

complete prehire file to the components for their investigation and 

adjudication. This integrated customer service effort could 

improve the efficiency of the personnel security process by 

streamlining functions, eliminating duplication, improving 

transparency, and enhancing customer service. 

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We recommend that the Under Secretary for Management: 

Recommendation #3: Create a centralized department-level 

personnel security intake processing and customer service center 

within DHS, administered by the DHS Personnel Security 

Division. 

Database Functionality 

Before 2008, components used individual databases to manage 

casework because DHS did not have a common data management 

system. Some components used legacy systems, often proprietary 

software, while others used commercial off-the-shelf software to 

build case-tracking capacity and meet individual needs. Figure 9 

lists the different systems in use prior to 2008. 

 Figure 9. The Various DHS Personnel Security Databases 

Component Data System 

CBP Consolidated Tracking System: A proprietary database 

used to track clearance and investigation requests 

FEMA 

Automated Personnel Security System: A legacy system 

used to track background investigations and 

adjudication determinations 

FLETC 

Federal Law Enforcement Training Center Clearance 

Database: A Microsoft Access database used to track 

background investigation and clearance information. A 

separate Microsoft database is used to track 

investigations. Both are legacy databases 

ICE 

Security Activities Reporting System: A repository for 

more than 150,000 ICE cases that interfaces with some 

other DHS systems 

PSD 

Personnel Security Activities Management System: 

A system used to automate the tracking and status of 

security clearance checks and associated activities 

TSA 

Background Investigation Tracking System: A Microsoft 

Access database that records and tracks case 

processing actions 

USCG 

CHECKMATE: An off-the-shelf system that contains 

information on the status of all initiated and completed 

background investigations, to include level of clearance 

USCIS 

Personnel Security System: A combination of the ICE 

Security Activities Reporting System and the Security 

Operations Reporting and Tracking System 

USSS 

Clearances, Logistics, Employees, Applicants and 

Recruitment: A headquarters management system to 

track both human resources and personnel security case 

processing 

 Source: OIG, derived from multiple sources. 

Increased reporting requirements and tightening timelines caused 

DHS PSD to develop the Integrated Security Management System 

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(ISMS).13 ISMS is an integrated web-based software system that 

captures data related to all aspects of suitability determinations and 

security clearance processing. ISMS is an enterprise-wide system 

for the entire DHS personnel security operation, and has the ability 

to support administrative security cases, security violation 

tracking, and secure document tracking. 

ISMS is planned to replace the components’ separate data systems. 

As of November 2008, component conversion to ISMS was being 

completed in phases. ISMS will allow users to share personnel 

security information on individual cases and aggregate information 

for statistical and reporting requirements. ISMS will give users the 

capability to update information, view case status online, and 

submit case status inquiries, as well as the ability to report on the 

number of security clearances issued within the department. DHS 

PSD, under OCSO, will also be better able to monitor submissions 

under IRTPA. As of November 2008, DHS PSD was using ISMS, 

and pilot programs had been launched at United States Customs 

and Border Protection (CBP) and the Federal Emergency 

Management Agency (FEMA). The United States Secret Service 

(USSS) and TSA were discussing strategies to integrate their 

current systems into ISMS. 

We recommend that the Under Secretary for Management: 

Recommendation #4: Consolidate component security 

information into ISMS. 

File Transfers 

Executive orders and OPM regulations require agencies to accept 

investigations conducted by other federal departments reciprocally. 

Reciprocity is a process designed to enhance the cost effectiveness 

of background investigations. However, during fieldwork, DHS 

component officials complained about the amount of time it took 

to obtain investigative files within DHS and from other federal 

agencies. Opinion varied within DHS as to which components 

took the longest to provide previous background investigations. 

All components noted the difficulty of obtaining investigative files 

from law enforcement entities in other federal agencies. 

ICE personnel security officials stated that they process most 

routine requests in 5 days. However, if a file had been archived, 

processing time could extend to 12 days. FEMA officials stated 

13 ISMS is not related to the Integrated Security Information Management System used by TSA. 

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that FEMA completes file transfer requests within 7 days. TSA 

indicated that most file transfers can be completed within hours 

upon request. USSS processes its file transfer requests in 30 days. 

The United States Coast Guard (USCG) transfers files within 17 

days. 

DHS PSD often processed file requests in 1 day. DHS PSD 

officials noted that the office does not have difficulty obtaining 

investigative files from other departments or DHS components. 

Because DHS PSD is part of headquarters and formally recognized 

by other federal agencies, information from other federal 

departments is easier to obtain. If DHS PSD was delegated intake 

responsibility for the entire department, there should be fewer 

delays in obtaining previous investigative files from other federal 

agencies and components. 

We recommend that the Under Secretary for Management: 

Recommendation #5: Designate the centralized intake processing 

center responsibilities for obtaining and coordinating interagency 

and federal department requests for previous investigation files. 

Alignment of Personnel Security Policies 

DHS components have been using legacy personnel security policies 

developed prior to September 11, 2001. Because DHS has not been 

proactive in developing new security policies, components have developed 

supplemental guidelines. Component officials would like DHS to 

standardize several security policies across the department. The alignment 

of DHS personnel security policies on reciprocity, adjudicator training, 

bad debt minimums, and temporary employees would solidify the DHS 

personnel security processes. 

Reciprocity Versus Suitability 

Figure 10 illustrates three situations where mission-specific 

suitability requirements and reciprocity may be problematic 

factors. In the first situation, an employee is transferring to a new 

position much like the former position. In the second situation, the 

new position has very different suitability requirements owing to 

the nature of the work. In the third situation, the new position has 

higher criticality and sensitivity. 

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Figure 10. Examples of Mission-Specific Positions and Additional Suitability Requirements 

for Employment 

Source: OIG, derived from multiple sources. 

The application of reciprocity arises only in cases where an 

employee is moving from one federal position to another. Each 

position has its own risk designation and position sensitivity. The 

thoroughness of the previous background investigation was based 

on the risk and sensitivity of the original position. The previous 

background investigation may not meet the requirements of the 

new position if the new position has a higher risk or sensitivity 

level. Although some components do not have additional missionspecific requirements and could easily implement reciprocity, 

many components have very specific mission needs that must be 

met. 

Applying Suitability Reciprocity 

A September 18, 2008, memorandum from the Under Secretary for 

Management formalized DHS’ commitment to implement 

suitability reciprocity within headquarters. DHS PSD will honor 

clearances held by employees in DHS components and from other 

federal agencies when the requirements for position sensitivity and 

access to classified information are the same. As of October 2008, 

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DHS PSD was the only component to outline formally how 

suitability reciprocity was to be applied within its office. 

Implementing suitability reciprocity within DHS components will 

be difficult. The selectee can be evaluated against the specific 

suitability requirements only once the background investigation is 

complete. DHS is a national security agency with multiple 

components, each with its own mission-specific suitability 

standards based on varied PDs. Following are examples of how 

suitability affects certain positions: 

�	 CBP Border Patrol agents are responsible for stemming the 

flow of illegal drugs into the United States. The agency 

seized more than 800,000 kilograms of illegal drugs in 

FY 2007. The opportunity for a Border Patrol agent to 

engage in illegal drug activity is high. Therefore, 

applicants are considered unsuitable for Border Patrol 

employment if it is determined that they have ever had any 

illegal involvement in the cultivation, manufacturing, 

distribution, processing, or trafficking of any drug or 

controlled substance. 

�	 USCIS employees administer immigration services and 

benefits, adjudicate asylum claims and petitions for 

nonimmigrant temporary workers, issue employment 

authorization documents, and adjudicate and grant lawful 

permanent resident status and citizenship. USCIS 

employees verify U.S. citizenship and status of any 

immediate family members or adults living with selectees 

and conduct checks on all foreign-born applicants, 

relatives, and close associates. The nature of USCIS duties 

makes it imperative that its employees have no association 

with illegal immigration activities. 

�	 TSA Transportation Security Officers are responsible for 

administering airport checkpoints across the United States. 

Because of their involvement with the flying public, and 

document and baggage checks, it is imperative the officers 

have been vetted for theft, burglary, or any interpersonal 

issues. 

�	 USSS special agents protect national leaders, visiting heads 

of state and government, and secure national security 

special events. It is imperative that USSS agents possess 

the utmost integrity. Although most background 

investigations do not require polygraph and medical 

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examinations, USSS requires its selectees to complete these 

examinations satisfactorily. 

To bring efficiency to the personnel security process, Executive 

Order 13467 clarified suitability reciprocity. The Executive order 

requires a background investigation for new security clearances, 

for clearances when the previous investigation is more than 5 years 

old, or for clearances when the previous investigation is not 

consistent with the position sensitivity level of the new position. 

Agencies are permitted to use additional mission-specific 

suitability requirements, but they must have the approval of either 

the OPM Suitability Executive Agent or the Security Executive 

Agent, as appropriate. 

We recommend that the Under Secretary for Management: 

Recommendation #6: Develop departmental guidance to apply 

reciprocity as outlined in Executive Order 13467. 

Recommendation #7: Designate the DHS Office of Security, 

Personnel Security Division as the DHS representative to the 

Suitability or Security Executive Agent to facilitate approval of 

additional DHS component suitability requirements. 

Understanding Suitability Reciprocity 

Most program managers are unaware of additional suitability 

requirements for certain positions. Personnel security offices, 

especially those with law enforcement responsibilities, must 

consider additional suitability requirements. From the program 

manager perspective, a security clearance is simply a background 

investigation. However, personnel security standards for a 

component may require additional suitability criteria that cannot be 

evaluated until a full background investigation is completed. 

The personnel security offices understand the program managers’ 

desire to bring selectees on quickly but feel they are being asked to 

place national security at risk simply to meet hiring requirements. 

Across components, it was evident that the personnel security 

offices were committed to ensuring that only fully vetted selectees 

received a favorable final adjudication. 

Component personnel security offices said it would be helpful to 

train program managers on the personnel security process. A 

training program that provided an overview of what personnel 

security is, how suitability is applied, and why extra processing 

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time is needed in some cases would increase program managers’ 

understanding of the personnel security process. Program manager 

training on the personnel security process should also reduce the 

number of customer service inquiries. 

We recommend that the Under Secretary for Management: 

Recommendation #8: Develop a training program for program 

managers on the personnel security process. 

Financial Disqualifiers 

As part of the application process, selectees are asked about their 

financial record. This includes whether they have had wages 

garnished or property repossessed, have filed for bankruptcy, or 

have other unpaid debts. Selectees must explain any delinquencies 

arising from federal taxes, loans, overpayment of benefits, and 

other debts to the federal government. They must also report 

defaults on federally guaranteed or insured loans such as student 

and home mortgage loans. The standards of ethical conduct for 

employees of the executive branch states: 

...employees shall satisfy in good faith their obligations as 

citizens, including all just financial obligations...especially 

those such as federal, state or local taxes...that are 

imposed by law.14 

Adjudicators must consider the nexus between the debt, the 

agency’s mission, and the position duties. Life events such as 

divorce or serious medical conditions that resulted in the 

accumulation of bad debt can be mitigated. Adjudicators are 

looking for a demonstrated intent by the selectee to rectify the 

debt. If the effort is not evident, an adjudicator can determine the 

selectee to be unsuitable strictly on the presence of the bad debt. 

The decision is based on the level of risk to national security and 

possibility that the selectee could be blackmailed or tempted to 

engage in illegal acts to generate funds. 

In setting bad debt criteria, some components linked the financial 

criteria to specific positions within the agency. Other components 

established debt ceilings and set a number of months or years after 

which the selectee must be debt free. These ceilings depended on 

the sensitivity of the position and included consideration of the 

security clearance. 

14 Title 5 CFR 2635. 

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Components use different non-risk based benchmarks to assess a 

selectee’s financial status. For example, CBP reviews individuals 

with past due debts of $5,000 or more, unpaid judgments, or courtordered obligations. USCG has established its outstanding debt 

threshold at $3,000. TSA uses a cumulative delinquent debt of 

$5,000 or more. Delinquent debt can be (1) any past due accounts 

that have been sent from a creditor to a collection agency or 

attorney for action; (2) any unpaid balance that has been reported 

as a loss to a creditor; (3) a repossession; (4) a court judgment that 

has not been satisfied; (5) a foreclosure on property or assets; or 

(6) any debts that have not been dismissed through a bankruptcy 

agreement. However, the amount of bad debt is not an automatic 

disqualifier since components use all available information to 

adjudicate a case. Figure 11 illustrates particular financial debt 

thresholds required by specific components. 

Both FEMA and USCIS want to qualify more applicants. FEMA 

has increased its acceptable debt limit to $10,000 if the debt is 3 or 

more years old or $5,000 if the debt is fewer than 3 years old. 

USCIS raised its debt ceiling from $1,000 to $3,000. 

Figure 11. Financial Threshold by Component 

Component Maximum Bad Debt 

CBP $5,000 

FEMA Fewer than 3 years old: $5,000 

Three or more years old: $10,000 

FLETC $3,000 

ICE 120 days or more delinquent: $5,000 

PSD $3,500 

TSA $5,000 

USCG $3,000 

USCIS $3,000 

USSS All bad debt must be mitigated 

Source: OIG, derived from multiple sources. 

Component officials expressed an interest in having a common 

maximum bad debt threshold across the department. Except for 

FEMA, the components’ maximum bad debt limits are similar. 

Components should have the latitude to increase the maximum bad 

debt requirement for their agency. Setting a common financial 

threshold across the department would facilitate reciprocity for 

intra-DHS assignments when the selectee’s job series and 

clearance level match the position’s requirements. 

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We recommend that the Under Secretary for Management: 

Recommendation #9: Establish a maximum bad debt amount for 

the department, and permit components to use less but not more 

than the maximum amount. 

Temporary Staff and Interns 

Temporary DHS employees and interns are generally subjected to 

less stringent background investigation requirements. There were 

no DHS standards for processing temporary or intern employees, 

so components have developed their own standards. Many DHS 

temporary employees and interns transition to full-time equivalent 

(FTE) employees at agencies. Inconsistent hiring processes for 

temporary or intern positions can add time to the hiring process. 

While most components require only preliminary checks for 

interns, some components process interns for secret clearances. 

The Federal Law Enforcement Training Center (FLETC) processes 

its student interns and summer hire program employees using a 

NAC. Requirements for FEMA’s disaster assistance employees 

(DAEs), a category of nonpermanent excepted service employees 

who are deployed during disasters, are legislated. DAEs do not 

hold security clearances because of the temporary nature of their 

disaster relief duties. FEMA vetting requirements for its 

temporary disaster workers were based on the length of the 

deployment period. DAEs with service of 180 days or more are 

vetted in the same manner as full-time federal civilian employees 

at FEMA. TSA performs a prehire suitability determination on all 

interns, summer hires, or volunteer personnel. Only if the 

individual will be returning to TSA for further assignment is the 

appropriate background investigation conducted. USSS not only 

conducts a limited background investigation on its student interns 

but also requires a favorable suitability and security clearance 

adjudication. 

We recommend that the Under Secretary for Management: 

Recommendation #10: Set minimum personnel security 

processing standards for temporary employees in DHS, to include 

student interns and summer hire program employees. 

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Adjudication Training 

Personnel security adjudicators review the completed background 

investigation and use appropriate suitability requirements to make 

a final determination on the character of the selectee. To make a 

final determination and issue a clearance, the adjudicator must be 

confident that the selectee does not pose a threat to national 

security. The ability to make a determination that is sustainable in 

court is vital to the adjudication position. 

The emphasis on adjudication training differs by component. DHS 

adjudicators receive training online, on the job, or in a classroom. 

The adjudication courses review adjudication guidelines and 

personnel investigations, and provide instruction on resolving 

cases with complex issues. 

Each component personnel security office has developed 

individual adjudicator training requirements. For example, FEMA 

adjudicators take 24 hours of training online through DHS and 

other sources. As of July 2008, FLETC requires adjudicators to 

take a class on fraudulent document detection and complete 

external training courses. In contrast, ICE has an internal training 

program that it augments with several external training resources. 

ICE hosts on-site training sessions for adjudicators and sends 

adjudicators to the United States Department of Agriculture 

Graduate School of Management, OPM training sessions, and a 4­

hour PSD class. TSA has also developed an in-house adjudication 

training program. Federal adjudication staff at TSA is required to 

attend beginning and advanced adjudication training on-site as well 

as that conducted by OPM. USCIS adjudicators receive training 

developed and taught by USCIS adjudication supervisors 

immediately upon assignment to the position. To ensure that those 

who provide customer services understand the adjudication 

process, USCIS provides an overview to its administrative support 

employees. 

Since adjudication determinations are subject to review or appeal 

and may be overturned in legal proceedings, the components must 

ensure that adjudications are made according to statutory and 

agency mandates. Unfavorable decisions are made to promote the 

efficiency of government service, and only after giving the 

individual due process rights. Unfavorable suitability decisions 

may be appealed to the Merit Systems Protection Board. Properly 

documented unsuitable determinations must meet legal standards 

in order to sustain denial. Many components conduct internal 

reviews on all denials and other adjudicative decisions to identify 

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areas where training or procedural changes would enhance 

adjudication decisions. These reviews usually include staff 

attorney examinations for legal sufficiency of the adjudicator’s 

written decision to deny the selectee. 

DHS OCSO has directed the DHS Training and Operations 

Security Division to provide training and awareness on missionbased security policies and procedures. The training office has 

dedicated one FTE to produce personnel security-related training 

courses for personnel security staffs. Using instruction developed 

in PSD by adjudicators, the training office has developed courses 

to address issues such as foreign influence, suitability, types of 

security clearances, and basic personnel security. 

Components provide their adjudicators with the tools necessary to 

make sound determinations. Several components told us that they 

had expressed to PSD a desire for a DHS adjudicator training 

certification program. In light of the Executive order requirements 

for reciprocity, a formal DHS adjudicator training program would 

provide assurance to components that DHS adjudicators have been 

trained to the same standard. 

We recommend that the Under Secretary for Management: 

Recommendation #11: Develop a formal DHS adjudicator 

training and certification program. 

Coordination of Key Operations 

Consolidating the intake function and aligning policies within the 

personnel security programs would give DHS an identifiable entity to 

coordinate actions with other federal agency and component personnel 

security offices. The coordination of key personnel security operations by 

DHS PSD would give components a single liaison for interaction with 

OPM. DHS PSD would be better able to work with the DHS Chief 

Human Capital Office (CHCO) on position designations and staffing 

needs. 

Interaction with the Office of Personnel Management 

OPM is the federal government’s human resource agency.15 

OPM classifies federal positions according to job duties and 

15 Executive Order 12107, December 28, 1978; Civil Service Reform Act of 1978 and Section 403 of 

Reorganization Plan Number 2 of 1978. 

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responsibilities and contracts with nongovernment providers for 

background investigations. OPM is responsible for the 

development of the e-QIP program and provides approximately 

90% of the investigative services used by all federal agencies. 

Delegation of Investigative Authority 

In June 2005, OMB assigned OPM responsibility to develop and 

implement uniform policies for timely completion of background 

investigations. In turn, OPM authorized a number of federal 

entities to administer the background investigation process. 

Currently, DHS components requesting investigative authority 

must annually submit requests through DHS PSD. DHS PSD 

consolidates the requests and submits them to OPM. As of 

September 23, 2008, CBP, PSD, USCG, and USSS were delegated 

background investigative authority by OMB.16 ICE, however, has 

legislated authority to conduct its own background investigations.17 

CBP and ICE contracted background investigations with several 

private companies. USCG and PSD use a mix of contractor and 

OPM investigative services. USSS uses internal resources to 

conduct background investigations, including administering 

polygraph examinations. 

Recommendation #12: Retracted. 

The e-QIP System 

The electronic Questionnaire for Investigations Processing system 

(e-QIP) was designed to electronically capture and transmit 

personnel security information. The system transmits information 

that is immediately accessible to eligible users, including the 

applicant. e-QIP eliminates mailing paper forms, and simplifies 

and automates record keeping. The system was created as one of 

OPM’s early steps in automating the personnel security process. 

Under e-QIP, agencies agreed to submit data and forms for 

background investigations electronically within 14 days. 

Although in existence since 2003, e-QIP was not widely used by 

agencies until 2006, when IRTPA mandated the initial reporting 

phase for collecting timeliness processing information. In 

December 2005, DHS was using e-QIP to transmit only 6% of its 

investigations. One year later, DHS transmitted 64% of its 

background investigations through e-QIP. DHS is currently one 

16 OMB Letter to OPM, October 29, 2007. 
 17 Public Law 109-90, House Report Number 109-79. 


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component away from being 100% compliant in e-QIP usage. At 

the time of our fieldwork, that component was negotiating with 

OPM on system security enhancements. 

The e-QIP system provides information on the timeliness and 

accuracy of submissions. DHS components use the information to 

measure progress and make procedural improvements. DHS 

security officials said that e-QIP improved the overall application 

process. However, components identified areas of persistent 

problems with e-QIP. For example: 

�	 e-QIP data fields are sensitive to small inconsistencies or 

errors. 

�	 Reportedly, the system frequently returns applications to 

the applicant without notifying the component. 

�	 e-QIP times out and erases applicant records. Some 

applicants have had to start their application over. 

�	 Contractors do not have access to e-QIP, and components 

using contracted investigators have to print paper copies for 

investigation. 

�	 Prior to e-QIP, the Standard Form 86 was 12 pages. With 

e-QIP, Standard Form 86 is more than 40 pages. 

�	 Errors detected in e-QIP are time consuming for 

components to correct. Neither the applicant nor HR can 

correct erroneous birthdates or the spelling of a last name. 

OPM electronically rejects or returns inaccurate e-QIP 

transmissions to the selectee. When an e-QIP submission is 

rejected, the file images are not viewable and the applicant must 

reinitiate the process. In some cases components do not have 

sufficient time to correct an error before e-QIP rejects the case. 

Some components received 10 to 15 rejections each week. 

Problems with an e-QIP submission must be resolved before the 

investigative phase can commence. When components do not 

understand the reason for the rejection, they call the e-QIP help 

desk. Component officials told us that they suspect that OPM is 

inundated with e-QIP support requests, but did not know for sure. 

Some component officials consider the e-QIP help desk staff 

unresponsive. According to these officials, e-QIP help desk staff 

could not explain why a form had been returned. The help desk is 

manned by contractors and, because of frequent contractor 

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rotation, it is difficult for components to follow up on cases. The 

time required to resolve discrepancies results in delays in initiation 

of the personnel security process. 

We recommend that the Under Secretary for Management: 

Recommendation #13: Develop a list of department concerns 

regarding e-QIP to share with OPM for resolution. 

Investigations 

IRTPA required that by 2006, 80% of personnel security 

investigation requests be completed within 90 days, and that by 

2009, 90% be completed within 40 days. Figure 12 shows the 

average number of days it took the components to complete 

investigation requirements in 2007 and 2008. Few DHS 

components meet the IRTPA requirements. We observed that 

DHS’ own contract investigations generally take 90 days or less, 

but those done for DHS by OPM usually take longer. Figure 12 

compares investigation processing times between contractors and 

OPM by component. 

Figure 12. Investigation Processing Times in Days 

Contractors OPM 

Component 2007 2008 Component 2007 2008 

CBP 97 59 PSD 101 67 

ICE 52 39 FEMA 121 94 

USSS 30–45 30–45 FLETC Not 

Available18 

TSA 130 96 

USCIS 110 82 

USCG 122 80 

Source: OIG, derived from multiple sources. 

There are mixed opinions among component officials regarding the 

adequacy and quality of OPM investigations. Some officials said 

that OPM investigators are inexperienced and may not know the 

proper questions to ask. Other officials, however, expressed 

complete satisfaction with OPM investigations. A determination 

regarding the sufficiency of OPM investigations was not within the 

scope of our review. 

18 FLETC data are not available because the FLETC Personnel Security Office was not staffed until early 

2008. 

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Components that use contracted background investigation services 

have stated that the investigations are complete and very thorough. 

There were few instances when a product was returned for further 

work; however, products were usually returned within 1 week. 

Components pay for all investigative services, OPM or contracted. 

A number of components expressed interest in negotiating with 

OPM on the type of information covered in a background 

investigation. Allowing a single entity like DHS PSD to liaise 

with OPM on personnel security issues would ensure a balanced 

approach to issue resolution. Placing DHS PSD in a direct liaison 

role with OPM would facilitate the delegation of investigative 

authority and faster resolution of e-QIP issues. 

We recommend that the Under Secretary for Management: 

Recommendation #14: Develop a list of department concerns 

regarding background investigations to share with OPM for 

resolution. 

Recommendation #15: Designate DHS Office of Security, 

Personnel Security Division, as the sole representatives to OPM for 

the components. 

Connection to DHS Chief Human Capital Office 

DHS CHCO is responsible for all DHS’ human resources issues, 

which include developing performance measures and enterprise 

human resource systems, training, and recruiting. Component 

officials described the relationship between the CHCO and DHS 

components as consultative. Component HR offices noted that the 

CHCO is understaffed and at a disadvantage in providing needed 

service. To date, the CHCO Recruitment and Staffing office has 

not been involved with position designation and classification at 

the component level. The CHCO does not have the federal staff 

necessary to coordinate component actions on position designation, 

a PD library, or workforce projections. Until CHCO can to 

provide appropriate position designations, a PD library, and 

workforce projections across the department, personnel security 

offices cannot function effectively. 

Verification of Position Designations 

The personnel security process starts when the program manager 

prepares the PD. In addition to containing a description of job 

duties, the PD states the sensitivity level of the position. The type 

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of background investigation that will be required must always 

correspond to the sensitivity level in the PD. Background 

investigations for sensitive positions those that require security 

clearances are usually both costly and time consuming. It is 

important that the sensitivity levels correctly reflect the duties of 

the job and be consistent with national security clearance access 

criteria. 

Inaccurate sensitivity levels compromise the personnel security 

program, increase costs, and lengthen investigation times. On the 

one hand, if a position’s sensitivity is understated, the selectee will 

be given a less complete investigation. This will result in issuance 

of an insufficient security clearance, prohibiting the selectee from 

performing the duties of the position. On the other hand, if a 

position’s sensitivity is overstated, the selectee will undergo a 

more expensive and protracted investigation than necessary and 

will receive a security clearance beyond what is required for the 

position. 

HR classifiers determine final position risk and sensitivity 

designation. Of the components included in our review, only three 

had classifiers. USSS has a classification branch with five 

classifiers. USCG has nine classifiers assigned to its HR offices. 

TSA had multiple classifiers to review position sensitivity. The 

CHCO has one classifier on staff. USSS, USCG, and TSA use 

their classifiers to review and validate position sensitivity. 

Components with classifiers on staff deem the role critical to 

ensure the proper designation of positions. DHS CHCO officials 

expressed concern about the absence of department grading 

standards and instructions for classification of PDs. We were told 

by the CHCO that a class on how to make position designations 

was offered to classifiers but only one individual attended. 

HR offices without classifiers rely on program managers to certify 

the accuracy of the position classification. One HR manager said 

that the classification occupation is perceived as less important 

than other HR areas. According to personnel security and HR 

officials, qualified classifiers are difficult to find and were 

described as a “dying breed.” Components without HR classifiers 

are uncertain who has responsibility for PDs. Personnel security 

and HR offices observed that program managers frequently do not 

understand the value of position designation. Many DHS 

component officials rely on their knowledge of position 

designation as it applied in legacy organizations. For example, as 

of August 2008, one component was using criteria developed by 

the National Aeronautics and Space Administration to establish 

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position risk and sensitivity designations. Another component was 

using a Department of Treasury form to classify positions. Others 

were using the Department of Treasury manual to make position 

risk and sensitivity designations. 

Personnel security officials said that some program managers want 

to adjust position clearance levels. To hire an employee, some 

program managers request a low designation, hire the individual, 

and then resubmit the position for an upgraded security clearance 

level. Other program managers insist on a higher clearance level 

to attract or retain an already cleared individual. Personnel 

security officials said that discussions take place with HR 

regarding the inappropriate designation levels. The HR office then 

discusses the matter with the program manager for resolution. 

Requests by program managers to upgrade clearance levels without 

full justification compelled TSA to develop a position sensitivity 

policy. The policy requires that TSA HR make the final decision. 

The TSA guidance supplements a DHS personnel security 

directive, which authorizes the program manager to designate 

position sensitivity. The DHS management directive states that 

sensitivity designations are subject to final approval by the 

organizational element’s respective Personnel Security Office.19 

However, the directive does not clearly state the role of the human 

resource classifier. 

DHS CHCO has placed the OPM requirements for position 

designation online. Some components, like USCIS and TSA, have 

developed and augmented their websites with information on the 

position designation and sensitivity process. Component officials 

would like clarification on making the final position designation. 

We recommend that the Under Secretary for Management: 

Recommendation #16: Direct component human resource offices 

to use a qualified classifier as the final decision maker in position 

designations. 

DHS Position Description Library 

A PD is the source document that lists the sensitivity designation 

and indicates to the personnel security officer the level of the 

security clearance to process. Many HR officials stated that DHS 

CHCO has not emphasized consistent application of federal 

19 DHS Management Directive 11050.2. 

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regulations or developed department policies on writing PDs for 

the components. 

The development and use of PDs vary among components. Some 

HR offices were using legacy PDs to fill vacancies. In other HR 

offices, program managers would identify a particular individual 

and then ask HR to write a PD to fit the position. Of all the 

components, only TSA classifiers reviewed positions whenever 

there were significant changes in duties or when employees were 

promoted. Although DHS CHCO has not required components to 

review old PDs, a departmental review of PDs would more 

accurately reflect security requirements of DHS’ positions. The 

CHCO should consider a 100% validation of PDs to ensure that 

sensitivity levels are appropriately designated. The HR 

community could conduct this task in cooperation with program 

managers and in coordination with personnel security offices. 

Unlike many federal departments, DHS does not have a PD library. 

A PD library is a collection of description templates and sample 

standardized PDs that program managers can download, use, and 

edit. A DHS PD library would simplify the classification process 

as it would contain standard description of duties, grading, and 

sensitivity designations for positions or series. A DHS PD library 

would also enable program managers to review existing PDs. 

We recommend that the Under Secretary for Management: 

Recommendation #17: Establish and maintain a department 

position description library of properly designated positions. 

Workforce Projections 

The CHCO and component personnel security offices need better 

information about future DHS hiring plans to staff their own 

offices properly. Personnel security offices cannot determine the 

appropriate size of their own staff without knowing the demand for 

services in the coming year. Inadequate staffing at personnel 

security offices often results in staffing shortages throughout the 

department. Because DHS CHCO does not collect workforce 

projections, some components conducted independent studies to 

determine security office staffing levels. 

TSA conducted an internal staffing assessment to identify the best 

possible realignment of FTEs and contractors. From July to 

October 2008, TSA’s backlog of cases to be adjudicated had 

grown from 2,000 to 5,000 cases. The average number of days to 

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adjudicate a case increased from 95 to 147 days. TSA 

implemented a night surge team and requested the transition of 

contractor adjudicator slots to full-time federal positions. In 2008, 

based on the results of the staffing assessment, TSA leadership 

agreed to provide 11 adjudicative and administrative FTEs to 

support the workload. 

ICE personnel security also conducted a review of the resources 

needed to meet agency hiring requirements. The personnel 

security officer required agency offices to submit their projected 

hiring needs. These projections were reconciled against the 

agency’s attrition rates, and ICE personnel security officials met 

with agency officials to discuss the cost of processing new hires. 

Agency leaders were willing to pay for contracted services if new 

hires could be on board within 60 days. Therefore, ICE personnel 

security negotiated four contracts for background investigations. 

Under these contracts, ICE background investigations are 

completed in approximately 37 days. The quick completion of the 

contractor-led investigations has allowed ICE adjudicators to issue 

final determinations more quickly. As of October 2008, ICE can 

have an individual investigated, adjudicated, and working in as few 

as 45 days if a case has no significant suitability issues. ICE was 

the only component that was confident that it could meet IRTPA 

requirements. 

FEMA also completed an internal staffing review to determine the 

number of additional adjudicators it needed to comply with the 30­

day IRTPA requirement. The study validated a need for three 

additional full-time adjudicators. Although initial funding was not 

available, as of October 2008, FEMA was in the process of 

developing a contract to provide administrative support for 

adjudicators so their primary workload could be adjudications. 

Only federal adjudicators can make final determinations. 

Adjudicator recruiting should be a priority as personnel security 

adjudication functions are understaffed. Adding contract staff 

support will expedite some support functions, but only federal 

employees have the right to adjudicate suitability. Any backlogs 

caused by caseload exceeding adjudicative capacity can only be 

relieved by hiring more federal adjudicators. Figure 13 shows the 

average adjudication processing time among DHS components. 

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Figure 13. Average Adjudication Processing Time in Days 

Component 2007 2008 

PSD 37 37 

CBP 62 79 

FEMA Not Available 

FLETC 55 37 

ICE 45 35 

TSA 95 147 

USCG 90 17 

USCIS 50 59 

USSS Continual Basis 

Source: OIG, derived from multiple sources 

Some components’ adjudication processing times have increased 

in the past year due to increased workloads. In June 2008, FEMA 

had five adjudicators and a backlog of 1,430 cases. By October 

2008, FEMA had only three adjudicators, and the number of 

FEMA cases awaiting adjudication grew to more than 1,900. 

Since May 2008, PSD has had the capacity to adjudicate 575 cases 

a month but received an average of 725 cases each month. In 

October 2008, TSA completed 2,000 cases in 1 month but, because 

of incoming cases, the backlog remained at 5,000. 

Both IRTPA requirements and expectations from program 

managers have forced personnel security officers to become better 

organized. However, not all personnel security offices have access 

to the workforce projections necessary to justify additional 

personnel security staff. Without accurate projections on FTEs, 

personnel security offices have a difficult time predicting future 

workloads or justifying the need for additional staff. 

DHS CHCO does not collect workforce projection numbers, which 

affects components’ ability to determine appropriate staffing levels 

for their own HR and Personnel Security units. With shorter 

IRTPA timeline standards, personnel security offices must have 

fully staffed offices. The department’s personnel security program 

cannot be fully successful without CHCO involvement. 

We recommend that the Under Secretary for Management: 

Recommendation #18: Direct DHS component HR offices to 

submit workforce projections to the Chief Human Capital Office 

annually. 

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Support of DHS Components 

At times, components need help with adjudications or guidance on 

how to meet federal requirements. DHS PSD informally provides 

adjudicator support to components and consults with components 

on program changes, and components keep DHS PSD apprised of 

developing personnel security situations. Further, DHS PSD can 

provide additional services to the components. Establishing an 

intake function would help accelerate the administrative processing 

of cases and would better enable DHS PSD to assist components 

with unexpected hiring surges and reinvestigation requirements. 

Surge Capacity 

DHS has experienced some significant yet unforeseen workload 

increases that may result from new programs or mandated 

requirements. Program surges significantly affect component 

personnel security offices. To assist components, DHS PSD 

provides vital surge capacity. 

The President’s FY 2008 budget proposal requested $647.8 million 

to hire 3,000 CBP Border Patrol agents. Subsequently, CBP was 

inundated with applicants seeking Border Patrol agent positions. 

To help with the influx, CBP enlisted DHS PSD and USCG’s help 

with adjudicating the investigations. DHS PSD and USCG 

adjudicators assisted with the CBP workload through voluntary 

overtime. 

FEMA has also used adjudicator resources from DHS PSD. When 

natural disasters occur, FEMA is responsible for getting a number 

of temporary employees cleared and to the disaster site in a short 

time. FEMA has sought and DHS PSD has provided adjudicative 

assistance in these situations. 

In 2008, the National Protection and Programs Directorate was 

directed to hire an additional 200 employees by the end of the 

fiscal year. As of September 2008, the directorate was attempting 

to coordinate hiring efforts with the CHCO to meet the mandate. 

At the time we concluded our fieldwork in October 2008, DHS 

PSD had not yet received any of the 200 applications. 

Currently, components must develop an agreement with PSD to 

obtain surge assistance. It is often time-consuming to negotiate the 

agreements. If PSD had a formal surge adjudicator capacity, it 

could offer adjudication more quickly through the intake office as 

a support feature. 

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We recommend that the Under Secretary for Management: 

Recommendation #19: Instruct DHS Office of Security, 

Personnel Security Division to formalize its provision to 

components of adjudicator surge capacity. 

Reinvestigations 

Periodic reinvestigations to assess an employee’s continued 

eligibility for access to classified information are critical to the 

personnel security process. The type of security clearance held by 

the employee determines when a reinvestigation is required. 

A periodic reinvestigation requires that the employee complete the 

same forms collected for the initial investigation. Either HR or the 

personnel security office notifies the employee that a 

reinvestigation of personnel security is required. Typically, the 

notification is accompanied by a request that the employee update 

Standard Form 86 via e-QIP. Employees who delay submitting the 

requested forms delay their readjudication, jeopardizing their 

continued access to classified information. 

With full implementation of ISMS, DHS PSD could oversee the 

department’s reinvestigation process. With more than 75,000 

employees maintaining security clearances and the need to 

reinvestigate every 5 to 10 years, many DHS employees need 

readjudication. The reinvestigation requirement increases the 

workload of the components. Under a centralized intake function, 

DHS PSD could initiate and consolidate component surge requests 

and reinvestigations. 

We recommend that the Under Secretary for Management: 

Recommendation #20: Require DHS Office of Security, 

Personnel Security Division to use ISMS to initiate and track 

reinvestigation needs for components. 

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Management Comments and OIG Analysis 

The recommendations in this report are made to the Under Secretary for 

Management. Compliance will require action by the Office of the Chief Security 

Officer on recommendations 1 11, 13, 14, 15, 19, and 20, and action by the Chief 

Human Capital Officer on recommendations 16, 17, and 18. 

Department management provided a complete and detailed response to our draft 

report, which we have attached as Appendix B. Though not required, the 

response includes not only the reply from the OCSO but also comments submitted 

to that office by USSS, USCIS, CBP, and ICE. Technical comments and 

corrections were received from CBP, FLETC, ICE, PSD, TSA, USCG, and 

USCIS. Where appropriate, we made changes to ensure the accuracy of 

information. As a result of these exchanges of updated information, we removed 

the recommendation that appeared in our draft report as recommendation number 

12. To preserve the sense of the management comments, which were written to 

respond to the draft, we have not renumbered recommendations 13 20. 

We recommend that DHS OCSO exercise the full range of authorities it has been 

given under MD 121-01 and MD 11050.2. Fulfilling its role will cause PSD, as 

part of the OCSO, to serve as both a departmental personnel security processing 

center and a representative for all DHS personnel security issues. PSD should 

have full awareness of how each component processes personnel security requests 

and serve as a resource to the OCSO on personnel security operations across the 

department. This would include standardizing, consolidating, and integrating 

DHS personnel security functions. We understand that component-level 

personnel security offices are reluctant to cede to the department many tasks and 

responsibilities they now perform for themselves, some of which are not 

substantially component-specific. Nevertheless, components’ willingness to 

continue to perform individually tasks that could effectively be centralized is not, 

in our opinion, a persuasive reason to accept continuing fragmentation of the 

department’s personnel security customer service processes. 

We also identified a number of HR functions the CHCO has not completed that 

significantly hinder the personnel security process. As these functions are 

essential to ensuring national security, we encourage the CHCO to undertake 

remedial action. 

Recommendation #1: Establish a department-wide requirement for selectees to 

complete e-QIP within a specified number of days, and develop strategies to 

manage selectees who do not meet the response requirement. 

OCSO Response: OCSO concurred with recommendation #1. In its response, 

OCSO management said that the CHCO allows each applicant 10 days to 

complete e-QIP after making a tentative job offer. OCSO said that if the 

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applicant fails to complete e-QIP within the required timeframe, the CHCO has 

the authority to rescind the offer of employment. 

OIG Analysis: This recommendation is resolved, open. Managers in 

components with more qualified applicants than vacancies can feel frustrated 

when an individual selected for a vacancy fails to complete the e-QIP process 

within the allotted time. Conversely, managers in components with more 

vacancies than qualified applicants are willing to tolerate such delays. Therefore, 

we are not recommending that the department arbitrarily impose a 10-day e-QIP 

completion deadline on selectees. We do recommend that the department develop 

an acceptable baseline, communicate it to selectees, and develop a strategy for 

dealing with selectee-caused delays. We understand that components need to be 

able to manage exemptions related to hard-to-fill positions. However, a baseline 

is important to maintaining efficiency in the personnel security process. The 

recommendation will remain open pending the receipt of a department-wide 

policy establishing a baseline for e-QIP completion. 

Recommendation #2: Delegate all customer service responsibilities to the DHS 

Personnel Security Division. 

OCSO Response: OCSO concurred in part with recommendation #2. In its 

response, OCSO management said each component has unique characteristics and 

operating requirements that would make a central customer service office 

impractical. Furthermore, OCSO management said a central customer service 

office to address e-QIP questions, such as password and golden questions resets, 

could be a viable alternative following a resource and process analysis. 

OIG Analysis: This recommendation is resolved, open. Our report provides a 

general resource and process analysis that could be used to initiate a departmentwide personnel security customer service office administered by PSD. We did 

not include specific details on implementation of this recommendation, but are 

concerned that personnel security offices do not fully understand our intent. 

We considered several of the component customer service functions as best 

practices from which the entire department would greatly benefit if uniformly 

applied. It is possible to use documents already developed by components to 

implement a customer service function at the department level. It is important 

that DHS provide consistent customer service on personnel security issues not 

only to applicants but also to program managers. The recommendation will 

remain open pending receipt of documentation of implementation plans to 

develop a department-wide personnel security customer service function for all eQIP responsibilities. 

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Recommendation #3: Create a centralized department-level personnel security 

intake processing and customer service center within DHS, administered by the 

DHS Personnel Security Division. 

OCSO Response: OCSO concurred in part with recommendation #3. In its 

response, OCSO management said implementation of this recommendation would 

require a significant reallocation of resources and space, and a comprehensive 

study should be conducted to determine feasibility. In addition, input would be 

needed from the chief information officer and information technology support 

offices. OCSO noted in its comments that some components did not believe that 

a centralized intake processing and customer service center would yield the 

efficiencies cited in the report. 

OIG Analysis: This recommendation is unresolved, open. A few components 

have concerns that implementation of our recommendation could result in a loss 

of control and initial processing delays. These components have developed their 

own capable personnel security programs incorporating prehire customer service 

tasks. Elevating their skills and best practices to a department-wide level would 

benefit all of DHS. Many smaller components need the resources to address their 

customer service needs thoroughly. When the tools, documents, and procedures 

already optimized by some large components are exported to a new, vitalized 

customer service function at the department level, the smaller components can be 

among the first to benefit. After the office is established, larger components can 

incorporate their customer service tasks. The potential value of providing 

consistent customer service on personnel security issues not only to applicants, 

but also to DHS program managers, should not be understated. We do not 

envision removing components’ ability to apply mission-specific requirements to 

their process. We encourage OCSO to consult component processes to develop a 

department-level personnel security intake processing center. The 

recommendation will remain open pending receipt of the results of a 

comprehensive study to determine the feasibility of implementing this 

recommendation. 

Recommendation #4: Consolidate component security information into ISMS. 

OCSO Response: OCSO concurred, stating that it is currently merging FEMA 

and CBP security information into ISMS. FLETC, ICE, and USCG are scheduled 

for future rollout. 

OIG Analysis: This recommendation is resolved, open. We will close the 

recommendation upon receipt of documentation on the integration of TSA and 

USSS personnel security information to ISMS and proposed timeframe for 

completion. 

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Recommendation #5: Designate the centralized intake processing center 

responsibilities for obtaining and coordinating interagency and federal department 

requests for previous investigation files. 

OCSO Response: OCSO concurred with recommendation #5. In its response, 

OCSO management said the recommendation is being mandated by the 

Repository Working Group, a subgroup of the Joint Reform Team, which consists 

of personnel security experts from the Director of National Intelligence (DNI), 

OPM, OMB, and Department of Defense. The mandate requires all records 

created by December 15, 2009to be stored in an approved electronic format. The 

OCSO said that it has taken the appropriate steps to implement the mandate. 

OIG Analysis: This recommendation is resolved, open. The Joint Reform Team 

is working to address issues regarding existing investigative files kept by other 

agencies. We encourage OCSO to take the lead on this important departmentwide issue, and incorporate the responsibility for transferring previous 

investigation files into the centralized intake processing center. The 

recommendation will remain open pending the receipt of documentation of a DHS 

policy to obtain and coordinate interagency and federal department requests for 

previous investigations. 

Recommendation #6: Develop departmental guidance to apply reciprocity as 

outlined in Executive Order 13467. 

OCSO Response: OCSO concurred with recommendation #6. In its response, 

OCSO noted the Joint Reform Team is developing guidance on application of 

reciprocity. 

OIG Analysis: This recommendation is resolved, open. The Joint Reform Team 

is working to address this recommendation. We encourage OCSO to develop a 

department-wide policy on reciprocity. DHS PSD has already developed a policy 

that could be applied department-wide. The recommendation will remain open 

pending receipt of documentation of a DHS policy for application of reciprocity. 

Recommendation #7: Designate the DHS Office of Security, Personnel Security 

Division as the DHS representative to the Suitability or Security Executive Agent 

to facilitate approval of additional DHS component suitability requirements. 

OCSO Response: OCSO concurred in part with recommendation #7. In its 

response, OCSO management said the DHS Chief Security Officer represents all 

DHS components on personnel security-related issues. 

OIG Analysis: This recommendation is resolved, open. In practice, OMB and 

OPM consider OCSO as the DHS personnel security representative. However, 

we were not provided any documentation recognizing OCSO as the DHS 

Suitability Executive Agent or Security Executive Agent. Further consideration 

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could also be given to designating PSD as the OCSO component liaison on all 

personnel security-related issues. The recommendation will remain open pending 

the receipt of documentation indicating that OCSO is the DHS representative 

authority for personnel security-related issues. 

Recommendation #8: Develop a training program for program managers on the 

personnel security process. 

OCSO Response: OCSO concurred with recommendation #8. In its response, 

OCSO management said the OMB Performance Accountability Council (PAC) 

has created a subcommittee to address the need to establish standardized training. 

The OMB PAC will mandate training and certification for all investigators and 

adjudicators. 

OIG Analysis: This recommendation is resolved, open. The OCSO response 

related to the development of training programs for investigators and adjudicators. 

In discussion with OCSO managers, we clarified that our recommendation was to 

develop a training program for program managers the supervisors whose staff 

vacancies were being filled by the new hires. Some personnel security officials 

told us that responding to repeated inquiries from managers eager to fill their 

vacancies was as burdensome as repeat inquiries from selectees. The 

recommendation remains open pending documentation indicating development of 

an informational module for program managers. 

Recommendation #9: Establish a maximum bad debt amount for the 

department, and permit components to use less but not more than the maximum 

amount. 

OCSO Response: OCSO concurred with recommendation #9. In its response, 

OCSO management said OCSO is reviewing debt levels in order to develop a 

proposed ceiling that is acceptable to the department. 

OIG Analysis: This recommendation is resolved, open. In discussion, OCSO 

noted that a memorandum was recently signed implementing this 

recommendation. We agree that the action OCSO plans to take will satisfy the 

intent of this recommendation. The recommendation will remain open pending 

the receipt of the signed memorandum documenting the department-wide bad 

debt maximum. 

Recommendation #10: Set minimum personnel security processing standards 

for temporary employees in DHS, to include student interns and summer hire 

program employees. 

OCSO Response: OCSO did not concur with recommendation #10. In its 

response, OCSO management said every agency vets its temporary employees 

and interns differently. OCSO noted that Title 5, CFR, Section 732 requires an 

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investigation only after 180 days of employment. Further, OCSO questions the 

value added to the personnel security process if this recommendation is 

implemented. 

OIG Analysis: This recommendation is unresolved, open. We understand that 

only employees who serve for more than 180 days are required to be vetted in the 

same manner as full-time federal civilian employees. However, under the 

management directives cited in this report, it is the responsibility of OCSO to 

issue, implement, and ensure compliance with written personnel security policies 

throughout the department. Our fieldwork identified component personnel 

security offices that were uncertain what the department required as a minimum 

for temporary employees. We encourage OCSO to consider using Homeland 

Security Presidential Directive 12 requirements to establish minimum processing 

requirements for temporary DHS employees. The recommendation will remain 

open pending receipt of documentation indicating that a department-wide 

minimum for temporary employees has been developed. 

Recommendation #11: Develop a formal DHS adjudicator training and 

certification program. 

OCSO Response: OCSO concurred with recommendation #11. In its response, 

OCSO said it provides adjudicator training at an annual security conference and 

quarterly at DHS adjudicator roundtable meetings. OCSO envisions developing 

additional adjudicator training to enhance OPM government-wide standards for 

adjudicator and investigator training and certification. 

OIG Analysis: This recommendation is resolved, open. Many components have 

developed adjudicator training programs that could be modified and certified at 

the department level. Some components indicated a willingness to assist with 

development, host a session, or serve as a pilot for such a program. The 

recommendation remains open pending receipt of documentation indicating that a 

DHS adjudicator training and certification program is being developed. 

Recommendation #12: Retracted. 

This recommendation was removed from the final report. DHS officials stated 

that OPM annually delegates investigative authority to DHS, and DHS is satisfied 

with OPM’s decisions with respect to delegated investigative authority. 

Recommendation #13: Develop a list of department concerns regarding e-QIP 

to share with OPM for resolution. 

OCSO Response: OCSO did not concur with recommendation #13. In its 

response, OCSO management said that it had no information suggesting e-QIP is 

not operating smoothly. 

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OIG Analysis: This recommendation is unresolved, open. As we reported, some 

selectees and DHS employees have experienced difficulties using the e-QIP 

system. OCSO should validate its assertion that e-QIP is operating smoothly by 

surveying DHS users to identify whether e-QIP issues exist within the 

department. Any issues noted should be conveyed to OPM. The recommendation 

will remain open pending the receipt of documentation on action taken by OCSO 

to bring department-wide e-QIP issues to OPM’s attention. 

Recommendation #14: Develop a list of department concerns regarding 

background investigations to share with OPM for resolution. 

OCSO Response: OCSO concurred with recommendation #14. In its response, 

OCSO management said the office, as part of a working group, is addressing the 

concerns of this recommendation. As a result, a survey and statistical analysis has 

been completed. 

OIG Analysis: The recommendation is resolved, open. We recognize that 

OCSO represents DHS regarding personnel security-related issues. However, our 

fieldwork identified a number of issues at the component level regarding 

background investigations. As noted in recommendation #3, the department’s 

fragmented approach to personnel security prevents OCSO from always being 

aware of department-wide issues. The recommendation will remain open pending 

the receipt of documentation of the survey and statistical analysis conducted, as 

well as documentation on action taken by OCSO to resolve department-wide 

background investigation issues. 

Recommendation #15: Designate DHS Office of Security, Personnel Security 

Division, as the sole representative to OPM for the components. 

OCSO Response: OCSO did not concur with recommendation #15. In its 

response, OCSO management said OCSO is a member of OMB PAC and of the 

DNI Special Security Center, and represents all DHS components on personnel 

security-related issues. OCSO and the components reported, however, that 

because each component has unique operational requirements, each must deal 

directly with OPM on specific case issues. The components want to retain their 

ability to deal directly with OPM on matters they consider specific to their 

organizations. 

OIG Analysis: This recommendation is unresolved, open. OCSO indicates that 

it uses various intergovernmental memberships to represent components on 

personnel security-related issues. Our fieldwork demonstrated that components 

contact OPM on the same issues. We recognize that components and OPM can 

quickly resolve some small, day-to-day issues , but the intent of this 

recommendation was to ensure a balanced approach to issue resolution. OCSO 

PSD has experienced fewer issues requiring OPM resolution than components. 

Our fieldwork indicated that the authority of OCSO has enabled PSD to resolve 

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issues more quickly than components. Designating PSD as the sole representative 

to OPM for the components could lend additional legitimacy to issues 

experienced by components and result in quicker resolution. The 

recommendation will remain open pending the receipt of a memorandum 

delegating authority to OCSO PSD as the sole representative for components on 

personnel security-related OPM issues. 

Recommendation #16: Direct component human resource offices to use a 

qualified classifier as the final decision maker in position designations. 

OCSO Response: OCSO reports that the CHCO concurred in part with 

recommendation #16. Its response said that the CHCO would need to establish 

FTE classifier positions in order to fulfill this recommendation and ensure 

continuity of operations. 

OIG Analysis: This recommendation is unresolved, open. The OCSO response 

addressed only the matter of adding qualified position classification specialists at 

the department level, not in the components. Our fieldwork has identified a 

significant need for qualified classifiers throughout the department to ensure the 

efficiency of the personnel security process. Without classifiers, positions can be 

filled using incorrect risk or sensitivity designations. Until this need is met, 

OCSO should assist in expediting the reallocation of department resources to 

include detailing experienced classifiers to components without classifiers. The 

recommendation will remain open pending our receipt of documentation that 

identifies the number of classifiers required department-wide, the proposed 

timeline for hiring new classifiers, and acknowledgment that classifiers have been 

placed in the components. 

Recommendation #17: Establish and maintain a department position description 

library of properly designated positions. 

OCSO Response: CHCO concurred in part with recommendation #17. In its 

response, OCSO management said that at least two teams need to be established 

to fulfill this recommendation. OCSO proposed an initial team of two classifiers 

to handle classification of position descriptions, ensuring that OPM guidance is 

followed. An undetermined number of classifiers on another team would identify 

the number of PDs to be reviewed and the timeframe of the review. Contractors 

could be used for administrative support between the two teams and to enter 

documentation into the newly developed CHCO PD library. 

OIG Analysis: This recommendation is unresolved, open. As noted in our 

report, we determined that some components use classifiers to review PDs. The 

CHCO should be able to request validated PDs from those components. Further, 

with implementation of recommendation #16, more components should be able to 

provide the CHCO with PDs that have been verified by detailed classifiers. These 

PDs could serve as the beginning of the DHS PD library and should be updated as 

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components make changes. This approach would reduce workload and use 

existing departmental resources. More important, it would facilitate quick startup 

of the PD library. We encourage the CHCO to work with component HR offices 

and to compile already validated PDs produced by qualified position classifiers. 

The recommendation will remain open pending receipt of PD templates with clear 

notation that the classification has been validated. 

Recommendation #18: Direct DHS component human resources offices to 

submit workforce projections to the Chief Human Capital Office annually. 

OCSO Response: OCSO concurred with recommendation #18. In its response, 

OCSO management said the CHCO needs to create a manning roster for each 

Directorate, by position. In addition, only vacant positions can be filled. It is 

expected that this will reduce unconstrained hiring. 

OIG Analysis: This recommendation is unresolved, open. While we encourage 

the CHCO to develop and maintain an electronic manning roster for the 

directorates, the CHCO’s proposed action would address only a portion of our 

concern. Workforce projections need to be obtained for all components, not just 

the headquarters directorates, and then shared with all personnel security offices. 

This will aid the department in acquiring sufficient qualified classifiers, 

adjudicators, and other staff to deal with future hiring activity. 

Implementation of this recommendation is essential to ensure appropriate 

planning and use of resources throughout the department. As the department’s 

human capital office, the CHCO has the authority to plan and execute departmentwide policies. We understand that the CHCO has experienced staffing 

limitations, but our fieldwork indicated that inadequate execution of HR policies 

can have a detrimental effect on other department programs. We saw this clearly 

in the personnel security programs. The recommendation will remain open 

pending documentation that describes the CHCO’s efforts to collect workforce 

projections from the department. 

Recommendation #19: Instruct DHS Office of Security, Personnel Security 

Division to formalize its provision to components of adjudicator surge capacity. 

OCSO Response: OCSO concurred with recommendation #19. In its response, 

OCSO management said that provision for a surge adjudication team was 

included in the FY 2010 budget but the funding had been dropped. DHS was in 

the process of appealing the decision. 

OIG Analysis: This recommendation is resolved, open. In discussion, OCSO 

said that the OMB decision to cut funding for a surge adjudication team was being 

appealed. The OCSO response did not indicate what the surge capacity would be, 

or how OCSO will overcome budget and operational requirements to implement 

this recommendation. We endorse the critical need for a surge adjudication team 

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to vet cleared selectees in a timely manner when department hiring initiatives 

overwhelm existing personnel security capacity. The recommendation will 

remain open pending receipt of documentation indicating the final appeal 

decision. 

Recommendation #20: Require DHS Office of Security, Personnel Security 

Division to use ISMS to initiate and track reinvestigation needs for components. 

OCSO Response: OCSO concurred with recommendation #20. In its response, 

OCSO management said implementation of this recommendation is under way. 

The first component is scheduled to begin using ISMS to track reinvestigations in 

April 2009. 

OIG Analysis: This recommendation is resolved, open. The action OCSO plans 

to take will satisfy the intent of this recommendation. OCSO should provide a 

timeline for inclusion of all components’ security information in ISMS, and a 

consolidated list of projected reinvestigations by component for FY 2010. 

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Appendix A 

Purpose, Scope, and Methodology 

The purpose of our review was to examine the department’s 

internal processes and standards for background investigations. 

This review did not evaluate the DHS personnel security clearance 

screening process for contractors, appointees, or nonfederal DHS 

employees. We measured DHS’ processing requirements, security 

clearance investigative authority, agency suitability requirements, 

clearance update requirements, and the application of reciprocity. 

Our report is based on interviews with key personnel security 

officials, human resources employees, and senior DHS officials. 

We conducted our fieldwork from June to August 2008. During 

this period, we received briefings from officials at the Office of 

Personnel Management and DHS Chief Human Capital Office, and 

conducted numerous interviews, including interviews with senior 

DHS Office of Security officials. We met with officials from PSD 

(which services all but eight of the DHS components) and spoke to 

officials from the following eight legacy personnel security offices 

within DHS: (1) United States Customs and Border Protection, 

(2) United States Citizenship and Immigration Services, (3) the 

Federal Emergency Management Agency, (4) the Federal Law 

Enforcement Training Center, (5) United States Immigration and 

Customs Enforcement, (6) the Transportation Security 

Administration, (7) the United States Coast Guard, and (8) the 

United States Secret Service. These offices provided insights into 

the effectiveness of the DHS personnel security process. We also 

interviewed department human resources officials and field office 

staff to learn about classification and hiring processes, and 

completed a Suitability Adjudications training course offered by 

the U.S. Department of Agriculture Graduate School. 

We studied related laws, regulations, Executive orders, and DHS 

management directives. We reviewed DHS guidelines and 

procedures, and analyzed DHS personnel security documents. In 

addition, we examined Government Accountability Office reports, 

relevant speeches, congressional testimony, and news articles. 

This review was conducted under the authority of the Inspector 

General Act of 1978, as amended, and according to the Quality 

Standards for Inspections issued by the President’s Council on 

Integrity and Efficiency. 

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Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Management Comments to the Draft Report 

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Appendix C 

Background Investigations 

Position Sensitivity National Security 

Information Access 

Background Investigation 

Minimum Standard 

National Security – Access to Classified Information 

Special Sensitive: 

Any position designated at a 

level higher than Critical 

Sensitive requiring access to 

Sensitive Compartmented 

Information and other 

intelligence-related Special 

Sensitive Information. 

Top Secret and more 

restricted Sensitive 

Compartmented 

Information. 

Single Scope Background 

Investigation: NAC reviews 

previous background 

investigations and law 

enforcement and intelligence 

agency records. Includes a 

check of cohabitants, personal 

interview, and record searches 

for the past 10 years. 

Critical Sensitive: 

Critical Sensitive positions 

have the potential for 

exceptionally grave damage to 

national security. 

Top Secret national 

security information or 

materials, or other 

positions related to 

national security that 

require the same degree 

of trust. 

Single Scope Background 

Investigation 

Non-Critical Sensitive: 

Non-Critical Sensitive positions 

have the potential for serious 

damage to national security. 

Access to Secret or 

Confidential national 

security information or 

materials, or duties that 

may directly or indirectly 

adversely affect national 

security operations. 

Minimum Background 

Investigation: NACI includes a 

personal interview and 

reference, credit, law 

enforcement agency, residence, 

and employment checks. 

Public Trust Law Enforcement or Fiduciary Responsibility 

High Risk: Potential for 

exceptionally serious Full Field Background 

consequences on the integrity Investigation: 

and efficiency of a service. 

Duties especially critical to the None Minimum background 

investigation covering 5 years of 

agency or program mission employment, residential, and 

with a broad scope of educational history. 

responsibility and authority. 

Moderate Risk: Considers the 

potential for moderate to 

serious affect on the integrity 

and efficiency of the service. 

Duties considerably important None Minimum Background Investigation 

to the agency or program 

mission with significant 

program responsibility or 

delivery of service. 

Non-Sensitive/Low Risk: 

Considers the potential for National Agency Check with 

limited affect on the integrity Inquiries: NACI and employment, 

and efficiency of the service. None education, law enforcement 

Duties and responsibilities of agency, and personal reference 

limited relation to an agency or checks. 

program mission. 

*Information in this chart was accurate as of March 2009. It is anticipated that changes will be made based 

on findings by the Joint Security and Suitability Reform Team. 

The DHS Personnel Security Process 


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Appendix D 

General Personnel Security Clearance Process Pos t on Des gnat on Background Invest gat on 

The DHS Personnel Security Process 

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Appendix D 

General Personnel Security Clearance Process 

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Appendix E 

Component Specific Personnel Security Information 

The following provides general information on the mission and role of component 

personnel security offices. The flowcharts do not include detailed decision points in the 

process nor variations applied for processing contractors. This information is current as 

of March 2009. 

DHS Personnel Security Division 

OCSO has oversight responsibilities for the DHS Personnel Security Program, to include 

issuing, implementing, and complying with policies and procedures. PSD is one of seven 

divisions under the DHS Office of Security. DHS PSD is responsible for developing and 

overseeing DHS personnel security policies governing background investigation and 

adjudications. PSD also manages and implements the employee suitability and security 

clearance program for all employees at headquarters. PSD develops department-wide 

security policies and assists the Administrative Security Division with compliance 

reviews. The Project Management Branch is responsible for developing enterprise 

systems and other special projects. Figure 17 describes the PSD workflow process. 

Figure 17. The DHS PSD Personnel Security Process 

Source: Data derived from DHS PSD documents. 

The DHS Personnel Security Process 

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Appendix E 

Component Specific Personnel Security Information 

United States Customs and Border Protection 

CBP is responsible for detecting and preventing illegal aliens, cargo, drugs, terrorists, and 

terrorist weapons from entering the United States. To achieve this goal, CBP Personnel 

Security Division (PerSec) is part of the Office of Internal Affairs and is responsible for 

the development of CBP policy and procedures, as well as the implementation and 

administration of all aspects of the Personnel Security Program. Figure 18 describes the 

CBP workflow process. 

Figure 18. The CBP Personnel Security Process 

Source: Data derived from CBP documents. 

The DHS Personnel Security Process 

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Appendix E 

Component Specific Personnel Security Information 

Federal Emergency Management Agency 

FEMA’s primary mission is to provide disaster assistance and protect the Nation from all 

hazards. This includes natural disasters, acts of terrorism, and other manmade disasters. 

FEMA PerSec is part of the Human Resources Office and operates under the Customer 

Service Unit. Figure 20 describes the FEMA workflow process. 

Figure 20. The FEMA Personnel Security Branch Process 

Source: Data derived from FEMA documents. 

The DHS Personnel Security Process 

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Appendix E 

Component Specific Personnel Security Information 

Federal Law Enforcement Training Center 

FLETC is responsible for training employees who support the federal law enforcement 

community. FLETC also provides services to state, local, and international law 

enforcement agencies. FLETC PerSec is part of the Security and Emergency 

Management Division. The FLETC PerSec mission is to ensure that only authorized 

personnel have access to FLETC facilities and sensitive but unclassified and national 

security information. FLETC PerSec adjudicates all investigations on FLETC federal 

and contractor employees. The FLETC PerSec Branch is organized into two units, the 

Federal Employee Unit and the Contractors Unit. Figure 21 describes the FLETC 

workflow process. 

Figure 21. The FLETC Personnel Security Process 

Source: Data derived from FLETC documents. 

The DHS Personnel Security Process 

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Appendix E 

Component Specific Personnel Security Information 

Immigration and Customs Enforcement 

ICE is responsible for identifying criminal activities and eliminating vulnerabilities that 

pose a threat to the Nation’s borders, as well as enforcing economic, transportation, and 

infrastructure security. ICE PerSec is responsible for processing personnel security 

investigations, adjudications, and reinvestigations on federal and contractor employees. 

PerSec has offices in Washington, DC; California; and Texas. Each ICE PerSec office is 

organized into the core four distinct functions for Intake, EOD, Investigations, and 

Adjudications. The DC office supports the entire investigative process. Figure 22 

describes the ICE workflow process. 

Figure 22. The ICE Personnel Security Unit Process 

Source: Data derived from ICE documents. 

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Appendix E 

Component Specific Personnel Security Information 

Transportation Security Administration 

TSA protects the Nation’s transportation systems to ensure freedom of movement for 

people and commerce. With state, local, and regional partners, TSA oversees security for 

the highways, railroads, buses, mass transit systems, ports, and U.S airports. TSA PerSec 

is located under the Office of Security. TSA PerSec is organized into two branches, 

Adjudications and Operational Support. Figure 23 describes the TSA workflow process. 

Figure 23. The TSA Personnel Security Process 

Source: Data derived from TSA documents. 

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Appendix E 

Component Specific Personnel Security Information 

United States Coast Guard 

USCG is a branch of the United States Armed Forces. It is unique in that it is also a 

maritime law enforcement agency and a federal regulatory agency under DHS. The 

USCG mission is to protect the public, the environment, and U.S. economic and security 

interests in any maritime region. The Coast Guard Security Center (SECCEN) in 

Chesapeake, Virginia, is the central adjudicating facility for the processing and 

maintenance of all USCG personnel security files. SECCEN is an operational division 

under the USCG Office of Security Policy and Management. SECCEN is functionally 

organized into three branches for uniformed members, federal civilians, and technical 

security employees. Figure 24 describes the USCG workflow process. 

Figure 24. The USCG Personnel Security Process 

Source: Data derived from USCG documents. 

The DHS Personnel Security Process 

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Appendix E 

Component Specific Personnel Security Information 

United States Citizenship and Immigration Services 

USCIS is charged with administering immigration services and benefits by processing 

immigrant visa petitions, naturalization petitions, and asylum and refugee applications. 

The USCIS PerSec, headquartered in Burlington, Vermont, is part of the Office of 

Security and Integrity. USCIS PerSec screening processes involve a security EOD and 

suitability determination for all federal and contractor applicants. USCIS PerSec also 

conducts internal selection, federal transfer approvals, and background investigation 

initiation. Figure 19 describes the USCIS workflow process. 

Figure 19. The USCIS Personnel Security Division Process 

Source: Data derived from USCIS documents. 

The DHS Personnel Security Process 

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Appendix E 

Component Specific Personnel Security Information 

United States Secret Service 

The USSS mission is to safeguard the Nation’s financial infrastructure and payment 

systems to preserve the integrity of the economy, and to protect national leaders, visiting 

heads of state and government, designated sites, and national special security events. 

USSS PerSec is one of three branches in the Security Clearance Division under the Office 

of Human Resources and Training. Figure 25 describes the USSS workflow process. 

Figure 25. The USSS Personnel Security Branch Process 

Source: Data derived from USSS documents. 

The DHS Personnel Security Process 

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Appendix F 

Major Contributors to This Report 

Douglas Ellice, Chief Inspector 

Megan McNeely Reedy, Lead Inspector 

Susan Fischer, Inspector 

Pharyn Smith, Inspector 

The DHS Personnel Security Process 

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Appendix G 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

Deputy Chiefs of Staff 

Acting General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

DHS Component Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

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ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4199, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.