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S. Hrg. 112–681 

SECURITY CLEARANCE REFORM: SUSTAINING 

PROGRESS FOR THE FUTURE 

HEARING 

BEFORE THE

OVERSIGHT OF GOVERNMENT MANAGEMENT, 

THE FEDERAL WORKFORCE, AND THE 

DISTRICT OF COLUMBIA SUBCOMMITTEE 

OF THE

COMMITTEE ON 

HOMELAND SECURITY AND 

GOVERNMENTAL AFFAIRS 

UNITED STATES SENATE 

ONE HUNDRED TWELFTH CONGRESS 

SECOND SESSION 

JUNE 21, 2012 

Available via the World Wide Web: http://www.fdsys.gov 

Printed for the use of the Committee on Homeland Security 

and Governmental Affairs 

( 
(II) 

COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS 

JOSEPH I. LIEBERMAN, Connecticut, Chairman 

CARL LEVIN, Michigan 

DANIEL K. AKAKA, Hawaii 

THOMAS R. CARPER, Delaware 

MARK L. PRYOR, Arkansas 

MARY L. LANDRIEU, Louisiana 

CLAIRE MCCASKILL, Missouri 

JON TESTER, Montana 

MARK BEGICH, Alaska 

SUSAN M. COLLINS, Maine 

TOM COBURN, Oklahoma 

SCOTT P. BROWN, Massachusetts 

JOHN MCCAIN, Arizona 

RON JOHNSON, Wisconsin 

ROB PORTMAN, Ohio 

RAND PAUL, Kentucky 

JERRY MORAN, Kansas 

MICHAEL L. ALEXANDER, Staff Director 

NICHOLAS A. ROSSI, Minority Staff Director 

TRINA DRIESSNACK TYRER, Chief Clerk 

JOYCE WARD, Publications Clerk and GPO Detailee 

OVERSIGHT OF GOVERNMENT MANAGEMENT, THE FEDERAL 

WORKFORCE, AND THE DISTRICT OF COLUMBIA SUBCOMMITTEE 

DANIEL K. AKAKA, Hawaii, Chairman 

CARL LEVIN, Michigan 

MARY L. LANDRIEU, Louisiana 

MARK BEGICH, Alaska 

RON JOHNSON, Wisconsin 

TOM COBURN, Oklahoma 

JERRY MORAN, Kansas 

CHRISTINE WEST, Counsel 

JENA MCNEILL, Professional Staff Member 

AARON H. WOOLF, Chief Clerk 
(III) 

C O N T E N T S 

Opening statement: Page 

Senator Akaka .................................................................................................. 1 

Prepared statement: 

Senator Akaka .................................................................................................. 25 

WITNESSES 

THURSDAY, JUNE 21, 2012 

Hon. Gene L. Dodaro, Comptroller General of the United States, U.S. Government Accountability Office .................................................................................. 3 

Hon. Daniel I. Werfel, Controller, U.S. Office of Management and Budget ....... 5 

Hon. Elizabeth A. McGrath, Deputy Chief Management Officer, U.S. Department of Defense .................................................................................................... 6 

Merton W. Miller, Associate Director, Federal Investigative Services, U.S. 

Office of Personnel Management ........................................................................ 8 

Charles B. Sowell, Deputy Assistant Director for Special Security, Office 

of the Director of National Intelligence .............................................................. 10 

ALPHABETICAL LIST OF WITNESSES

Dodaro, Hon. Gene L.: 

Testimony .......................................................................................................... 3 

Prepared statement .......................................................................................... 27 

McGrath, Hon. Elizabeth A.: 

Testimony .......................................................................................................... 6 

Prepared statement .......................................................................................... 63 

Miller, Merton W.: 

Testimony .......................................................................................................... 8 

Prepared statement .......................................................................................... 69 

Sowell, Charles B.: 

Testimony .......................................................................................................... 10 

Prepared statement .......................................................................................... 77 

Werfel, Hon. Daniel I.: 

Testimony .......................................................................................................... 5 

Prepared statement .......................................................................................... 55 

(1) 

SECURITY CLEARANCE REFORM: SUSTAINING 

PROGRESS FOR THE FUTURE 

THURSDAY, JUNE 21, 2012 

U.S. SENATE, SUBCOMMITTEE ON OVERSIGHT OF GOVERNMENT

MANAGEMENT, THE FEDERAL WORKFORCE, AND THE DISTRICT OF COLUMBIA, OF THE COMMITTEE ON HOMELAND SECURITY

AND GOVERNMENTAL AFFAIRS, Washington, DC. 

The Subcommittee met, pursuant to notice, at 2:34 p.m., in Room 

342, Dirksen Senate Office Building, Hon. Daniel K. Akaka, Chairman of the Subcommittee, presiding. 

Present: Senator Akaka. 

OPENING STATEMENT OF SENATOR AKAKA 

Senator AKAKA. This hearing of the Subcommittee on Oversight 

of Government Management, the Federal Workforce, and the District of Columbia is called to order. 

Aloha and good afternoon to all of you. Mahalo. Thank you very 

much for coming. I would tell you that this is a time for praise because so much has been done and so much needs to be done, too. 

But I think we are moving along the right course and I would like 

to think of it like a canoe. We are on the right course, so thank 

you. 

In 2005, the Government Accountability Office (GAO) placed the 

Personnel Security Clearance Process on its High-Risk List due to 

a massive backlog of applications and insufficient quality standards. This is the Subcommittee’s eighth hearing on the security 

clearance process since that time. 

In addition to GAO’s and the Subcommittee’s oversight, the Administration has placed long-term high-level focus on reforming the 

process, and I must commend you because, together, these agencies 

have made significant improvements. I am pleased to say that last 

year, the security clearance process was removed from GAO’s HighRisk List. The application backlog has been eliminated, and timeliness requirements in the 2004 Intelligence Reform Act have been 

met and exceeded. Today, initial investigations take an average of 

44 days to complete, compared to a staggering 189 days in 2005. 

That is the kind of progress we have made. 

Investigation quality improvements were another key aspect of 

removing the high-risk designation. In multiple reports, GAO had 

found that clearances were granted based on incomplete investigation files. Moreover, there was no way to evaluate the quality of se-
2 

curity clearance determinations to make sure security threats were 

consistently weeded out. Lapses in quality posed a national security risk. 

The Performance Accountability Council (PAC) has worked together to address all aspects of investigation and adjudication quality. The PAC has updated the security clearance application, improved interview techniques, and created quality metrics. Its members are working to standardize investigator training and to develop governmentwide adjudication guidelines. 

Despite considerable progress, challenges remain. Continued 

oversight and accountability are needed to sustain progress and 

momentum in the future. Reciprocity continues to be an issue. In 

our 2010 hearing, I urged agencies to work together to accept clearances from other agencies. This allows critical national security positions to be filled with the right people more quickly. 

Although progress has been made on this issue, establishing 

more uniform training, investigation, and suitability standards 

would increase trust between agencies and promote reciprocity. Additional information technology improvements also are needed to 

support information sharing and case management. Without these 

investments, further improvements in timeliness and reciprocity 

will be difficult to achieve. 

As you all know, this will be my last hearing on the security 

clearance process before I retire. Congressional oversight and sustained focus by the Executive Branch have produced a more efficient and functional security clearance process. I am proud of what 

we have accomplished together and hope that our work will serve 

as a model to address other high-risk areas in our Federal Government. 

I will continue to monitor this issue during my remaining time 

in the Senate and I hope that future Members of this Subcommittee continue to focus on this critical issue. I look forward to 

hearing from our witnesses on how they plan to build on this legacy and ensure the continued success of the security clearance 

process. 

It is my pleasure to again welcome our panel of witnesses to the 

Subcommittee today: Gene Dodaro, Comptroller General of the 

United States and head of the Government Accountability Office; 

Danny Werfel, who is the Controller at the Office of Management 

and Budget (OMB); Elizabeth McGrath, Deputy Chief Management 

Officer at the Department of Defense (DOD); Mr. Merton Miller, 

Associate Director of Federal Investigative Services (FIS) at the Office of Personnel Management (OPM); and Mr. Charlie Sowell, Deputy Assistant Director for Special Security at the Office of the Director of National Intelligence (ODNI). 

As you know, it is the custom of this Subcommittee to swear in 

all witnesses, so will you please stand and raise your right hand. 

Do you swear that the testimony you are about to give this Subcommittee is the truth, the whole truth, and nothing but the truth, 

so help you, God? 

Mr. DODARO. I do. 

Mr. WERFEL. I do. 

Ms. MCGRATH. I do. 

Mr. MILLER. I do. 
3 

1The prepared statement of Mr. Dodaro appears in the appendix on page 27. 

Mr. SOWELL. I do. 

Senator AKAKA. Thank you. Let the record show that the witnesses answered in the affirmative. 

Although statements are limited to 5 minutes, I want all of our 

witnesses to know that their entire statements will be included in 

the record. 

Mr. Dodaro, will you please proceed with your statement. 

TESTIMONY OF HON. GENE L. DODARO,1 COMPTROLLER GENERAL OF THE UNITED STATES, U.S. GOVERNMENT ACCOUNTABILITY OFFICE 

Mr. DODARO. Thank you very much, Mr. Chairman. Good afternoon to you. 

Senator AKAKA. Good afternoon. 

Mr. DODARO. I would like to start with the announcement of your 

retirement. First, on behalf of myself and all my colleagues at the 

GAO, thank you for your service to the country and for being such 

a steadfast proponent of improving management in the Federal 

Government. We have had the privilege of working with you on 

many issues, on our High-Risk list, human capital, nuclear-radiological issues, veterans’ issues, financial literacy, and the list goes 

on. Know, though, that when you leave the Senate, you leave with 

our deep appreciation for your dedication and with the best wishes 

from all of us to you and your family. 

Senator AKAKA. Thank you much. 

Mr. DODARO. I think today’s hearing is a really good example of 

what can happen when you have sustained high-level Congressional attention and active engagement with the Executive Branch, 

and when the Executive Branch gets organized properly to tackle 

a problem and gives dedicated, committed top-level leadership and 

proper resources, and there is the application of good management 

practices to tackle a problem at hand. 

As you pointed out, we put the area on the High-Risk List in 

2005 for various reasons—backlogs, incomplete investigations and 

adjudication documentation. Congress held a series of hearings, not 

only this Subcommittee, but other Committees, a total of 15 hearings from the time it was put on the list. The Administration organized into the Performance Accountability Council. Top-level officials were dedicated to it. They were supported by staff in their 

agencies. And metrics were set, which is very important, and that 

is what I meant by the proper application of management principles. And as a result of dramatic improvements in the timeliness 

of processing initial investigations from DOD, in particular, which 

covers the lion’s share of the investigation and clearances issues, 

and the establishment of these quality metrics in 2010, we felt 

comfortable removing the area from our High-Risk List with the 

proviso that there be continued attention and commitment on the 

part of the Executive Branch to do this. 

Now, the real challenge going forward will be to sustain the attention to this area and to enhance the efforts that have been put 

in place and to make sure that the continued improvements are 
4 

there and there is not any potential for there to be slippage in the 

progress that has already been achieved. 

And a few areas that I would point out that I think really need 

attention is, one, while quality metrics have been introduced, they 

need to be fully implemented and they need to be refined as the 

process unfolds and based on experience in applying the quality 

metrics and to make sure that they are used governmentwide, not 

just at DOD, ODNI and OPM. I think those would be key developments. 

Second, in terms of the fiscal pressures facing the Federal Government right now, I think there are opportunities for efficiencies 

to be gained in the process. I know OPM is looking now at efficiencies in their process and is supposed to have a report next year 

on that. We are encouraged by that development. We also pointed 

out in our recent report on overlap and duplication that there were 

five different agencies developing case management systems and 

we thought that there was a possibility for overlap and duplication 

in this area. We made a recommendation to OMB to establish policies so that agencies are leveraging off existing technologies and 

not making duplicative investments. We are encouraged OMB 

agreed with that recommendation and is moving to implementation 

in that area. I think that can save a lot of money, too. As we point 

out in our testimony, investments in information technology are 

one of the major cost drivers associated with processing clearances 

now. 

And then, finally, there needs to be continued attention to determining and having in place the right process for figuring out who 

should have a clearance in the first place, and to make sure that 

only the minimum number of people have them. I know in many 

cases, it is important to have the flexibility of having people with 

clearances, particularly at the ‘‘top secret’’ level, in carrying out the 

missions of the agencies, but there needs to be an initial process 

of determining what that number is and keep it at a minimum. 

The same is true of when reinvestigations have to be taking place 

and you have to go through the process over again. Further, there 

is a huge difference in the amount of money that is spent to process a ‘‘top secret’’ clearance versus a ‘‘secret’’ clearance, and so 

there are cost implications, as well. 

So in summary, Mr. Chairman, we are very encouraged by the 

progress, with the partnership in Congress and the Administration 

in this area. We felt comfortable enough to take it off the HighRisk List, but that does not mean we do not have a watchful eye 

on this going forward. Congressional oversight and continued attention by the Executive Branch are pivotal, and we will do our 

part, as well. 

So thank you very much. I would be happy to answer questions 

at the appropriate time. 

Senator AKAKA. Thank you very much, Mr. Dodaro. 

Mr. Werfel, please proceed with your statement. 
5 

1The prepared statement of Mr. Werfel appears in the appendix on page 55. 

TESTIMONY OF HON. DANIEL I. WERFEL,1 CONTROLLER, U.S. 

OFFICE OF MANAGEMENT AND BUDGET 

Mr. WERFEL. Chairman Akaka, thank you for inviting me here 

today. It is my privilege to testify on behalf of the Office of Management and Budget and to discuss the Administration’s ongoing 

security clearance reform efforts. 

This Administration has made important advances in reforming 

the security clearance process. There is still work to be done, but 

Federal hires, military personnel, cleared contractors, and those 

personnel requiring a reinvestigation have a more effective and expedient clearance experience than they did just a few years ago. 

For many years, a backlog in the government’s security clearance 

inventory caused tremendous problems and significant expense. 

Recognizing the breadth and depth of this problem, Congress took 

action. In 2004, the Intelligence Reform and Terrorism Prevention 

Act (IRTPA) challenged the Federal Government to address these 

issues, and in 2005, the GAO placed DOD’s Personnel Security 

Clearance Program on its high-risk list. 

In response, the Executive Branch took aggressive action to address the goals of IRTPA and tackle the backlog, and the results 

are clear. In 2005, the governmentwide average for initial clearances was 265 days. As recently as 2006, the backlog of pending 

clearance investigations over 180 days old stood at almost 100,000 

cases. By December 2009, 90 percent of the government’s initial 

clearances were completed within the IRTPA-required time frame 

of 60 days, and we have consistently met the IRTPA target since 

that time and the decades-old backlog of initial investigations is 

now gone. 

In addition, the Suitability and Security Clearance Performance 

and Accountability Council, was established in 2008 and is held accountable to the President for achieving security clearance reform 

goals. Since 2008, the PAC has aggressively taken on and met 

many reform challenges. 

In concert with the goal to increase the use of information technology in making the security and suitability clearance process 

more efficient, applicants are using an improved electronic questionnaire for national security positions. Investigators have increased access to electronic record repositories. OPM investigations 

are transmitted electronically. And the PAC has completed several 

promising pilots on the effectiveness of automated record checks 

and support of revised Federal investigative standards. The PAC is 

currently developing an implementation plan for a five-tiered investigative model that will streamline and facilitate greater reciprocity 

between suitability and security investigations and determinations. 

And perhaps most importantly, 90 percent of the security clearance 

determinations last quarter were completed within 46 days, an 83 

percent reduction from the 2005 level, exceeding the IRTPA timeliness standard. 

This is significant progress, and our ongoing efforts to sustain 

timeliness and ensure quality, led GAO to remove DOD’s Personnel 

Security Clearance Program from its high-risk list last year. Such 

impressive results are attributable to the skill and dedication of the 
6 

1The prepared statement of Ms. McGrath appears in the appendix on page 63. 

staff at the Defense Department, the Office of the Director of National Intelligence, the Office of Personnel Management, our partnership with GAO, and the leadership and persistent focus of Congress and this Subcommittee, in particular. 

Looking forward, in order to sustain this progress, we are focused 

on amending the investigative and adjudicative standards to make 

identified efficiencies permanent and supporting them with further 

technology improvements. In particular, we are pushing forward on 

three key areas. 

First, aligning suitability and security processes and policies 

through modification of regulatory standards, investigative standards, and information collection forms that underlie our clearance 

operations. 

Second, leveraging information technology (IT) solutions to improve timeliness, quality, and reciprocity, in particular, continuing 

to convert paper-based application processes to electronic questionnaires in the intelligence community (IC) and further connecting 

intelligence community and unclassified record repositories. 

And third, providing oversight of and assistance to agencies that 

are lagging behind in security clearance reform. 

In all these efforts, we will rely on the continued efforts and 

partnership of the PAC, oversight of the Security and Suitability 

Executive Agents, cooperative leadership of Executive Branch agency heads, as well as the accountability brought to bear by GAO and 

this Subcommittee to ensure that we stay on track and do not lose 

momentum. 

Without question, significant progress has been made to date in 

security clearance reform, but work remains in order to make that 

progress sustainable and that effort remains a high priority for this 

Administration and for me personally. 

With that in mind, before I close, I would like to take a moment 

to thank you, Mr. Chairman, for your leadership. We will lose a 

key partner when you leave the Senate, but we are proud to have 

accomplished so much and to have established this trajectory on 

your watch. We look forward to our continued work with your colleagues on the Subcommittee as well as my fellow witnesses who 

continue to drive forward the reform process through the PAC. 

Once again, thank you for the opportunity to testify and I look 

forward to answering your questions. 

Senator AKAKA. Thank you very much, Mr. Werfel. 

Ms. McGrath, will you please proceed with your statement. 

TESTIMONY OF HON. ELIZABETH MCGRATH,1 DEPUTY CHIEF 

MANAGEMENT OFFICER, U.S. DEPARTMENT OF DEFENSE 

Ms. MCGRATH. Thank you very much. Chairman Akaka, thank 

you for the opportunity to testify before you and the Subcommittee 

today on the Defense Department’s efforts toward reforming the 

personnel security clearance process. 

I, too, truly appreciate the Subcommittee’s leadership over the 

last few years. Your sustained attention has been tremendously 

valuable in ensuring that we continued our improvement in both 

timeliness and quality. And, sir, I want to specifically thank you 
7 

for your personal engagement in these efforts. I do not know that 

I have been to all of the eight hearings, but it feels like I have been 

to most of them, so thank you very much, because I think without 

your leadership and the leadership of the Administration and the 

Government Accountability Office, we would not be as far along 

today as we are. 

Since co-founding the Joint Reform Team 5 years ago, DOD and 

its teammates have accomplished quite a bit, as has been mentioned, streamlining policy and processes, reducing duplication and 

waste, strengthening governance through the Performance Accountability Council, which I believe is a model for effective interagency cooperation. 

The results are clear. The timeliness far exceeds, as you mentioned, sir, the goals set by the Intelligence Reform and Terrorism 

Prevention Act. We certainly do have a higher quality security 

clearance program today and we have better information technology that enhances capabilities across the Federal space, and certainly within the Defense Department. 

And I must also say that it has been a long desire of the Department to have at least one of its items removed from GAO’s HighRisk List. I mention our work in security clearance reform all the 

time a model for how that it is achievable. We have demonstrated 

that, and I look forward to taking more of our high-risk items off 

of that notorious list. 

These improvements to the security clearance process certainly 

have made great contributions to the DOD mission. It improves our 

ability to safeguard classified material, place qualified individuals 

into jobs faster, effectively utilize our contractor workforce, and reduce the burdens and inconveniences on both the Federal workforce and our military members. 

Our results present the progress that is possible when agencies 

commit to joint goals informed by governmentwide priorities and 

establish proper controls to ensure results. It has been an honor to 

serve not only as the DOD voice to this effort, but also as the Vice 

Chair of the Performance Accountability Council. We could not 

have achieved this project without the work of the organizations 

represented here today and the sustained leadership and focus of 

this Subcommittee. 

Specific to the Defense Department, I would like to highlight just 

a few things. Against the IRTPA goal to adjudicate cases in 20 

days, DOD’s statistic for adjudication gone as low as 7 days. It is 

extremely impressive. We did this through many different methods, 

both by looking at our process within the Defense Department but 

also infusing and implementing greater information technology. 

I want to highlight our electronic adjudication capability. In our 

Case Adjudication Tracking System (CATS), we were able to electronically adjudicate last year almost 100,000 cases representing 24 

percent of our ‘‘secret’’ workload to allow our adjudicators to focus 

on the more important cases. We have also offered that to other 

Federal agencies. The Department of Energy (DOE) has taken advantage of that capability with the Social Security Administration 

planning to implement next year. 

We have also implemented greater tools to ensure we have quality in place for both our adjudicative determinations and investiga-
8 

1The prepared statement of Mr. Miller appears in the appendix on page 69. 

tions we also have initiated a robust adjudicator certification program to ensure comprehensive and standardized training of all of 

our adjudicators. 

As has been mentioned, we still have things to do. Key to those 

are the policy initiatives, as Mr. Werfel mentioned, the Federal Investigative Standards, and adjudicative guidelines. We are very 

close to implementing both of those. Our governmentwide regulations put policy in place to ensure that we sustain this progress 

over the time horizon. We developed training standards from a national perspective, in order to reach not only the Department of Defense but also the Federal space. We are setting and reaching 

stretch goals in the area of information technology to truly enable 

our original vision of end-to-end automation. 

I do look forward to continuing to work with this Subcommittee 

in the future on these important issues, and again, Senator Akaka, 

I want to thank you very much for your personal engagement on 

this and other issues that I have the opportunity to talk to you 

about. I look forward to your questions. 

Senator AKAKA. Thank you very much, Ms. McGrath. 

Mr. Miller, will you please proceed with your statement. 

TESTIMONY OF MERTON MILLER,1 ASSOCIATE DIRECTOR, 

FEDERAL INVESTIGATIVE SERVICES, U.S. OFFICE OF PERSONNEL MANAGEMENT 

Mr. MILLER. Thank you, Chairman Akaka. On behalf of Director 

Berry, I want to thank you for the opportunity to testify today regarding OPM’s role in security clearance reform and our efforts in 

achieving and sustaining the tremendous progress made in the security clearance and investigation program. 

I am also very pleased to have the opportunity to thank Chairman Akaka and this Subcommittee for your sustained leadership 

in correcting a decades-old problem through investigative consolidation, legislated performance goals, and directly supporting security clearance reform efforts. 

Lastly, but most importantly, I am delighted to have the opportunity to thank Chairman Akaka, and with deepest gratitude and 

best wishes, mahalo nui loa, for his many years of noble and dedicated service to our country. 

Senator AKAKA. Thank you very much. 

Mr. MILLER. From the beginning, OPM has been deeply committed to working closely with our partners. The Office of the Director of National Intelligence and the Department of Defense, 

along with our other partners, have moved the security clearance 

program forward. We have implemented important reforms, and 

improved the timeliness, efficiency, and quality of the security 

clearance and background investigative process. 

It was not that long ago when Members of this Subcommittee 

were hearing testimony about significant and growing security 

clearance backlogs, inadequate resourcing to address the growing 

workload, increasing risks to national security because reinvestigations were delayed or not conducted at all, and the loss of billions 

of dollars of productivity because hundreds of thousands of Federal 
9 

employees, military members, and contractors experienced significant delays to obtain a clearance. The backlog was first formally 

recognized in 1981 and continued until 2009, when the program 

was finally current. 

While there had been continued reporting on the challenges associated with the background investigative program, it was not until 

legislation like the Intelligence Reform and Terrorism Prevention 

Act and E.O. 13381 that put this program on the right course. 

Today, OPM’s background investigative program performance is 

strong, demonstrated by years of providing timely, quality products 

to our 100-plus customer agencies. We have no backlogs, are meeting Congressional timeliness mandates, and we continue to increase automation to enhance performance, quality, timeliness, and 

reduce cost. The success of this program can be directly attributed 

to this Subcommittee’s leadership, OMB’s determined chairmanship of the Performance Accountability Council, and the strong 

partnership OPM has enjoyed with the DNI, DOD, and other Executive Branch agencies. 

Since 2005, OPM has seen our workload and field work intensive 

investigations increase significantly, with a 26 percent increase in 

‘‘top secret’’ investigations, a 21 percent increase in ‘‘secret’’ and 

‘‘confidential’’ investigations, and a 144 percent increase in ‘‘top secret’’ reinvestigations. Despite unpredictable workloads and projections and a shift in investigative requests towards more resourceintensive investigations, OPM has been able to improve investigative timeliness by 75 percent through appropriate levels of investment in Federal and contract staffing, training, and increased automation. More importantly, Federal, military, and government contract employees are getting to work more quickly, returning billions 

of dollars of previously lost productivity back to the Federal Government. 

As demonstrated by years of meeting PAC quality metrics and 

supported by continuing reform enhancements, the quality of our 

investigation program remains a top priority. We ensure the quality of our investigations products by actively pursuing feedback 

from our customers, maintaining a robust internal quality and integrity control program, and have invested heavily in standardizing 

training and the use of quality tools. Our strategies to continue to 

ensure an effective investigative staff includes targeted training enhancements, a realigned quality structure, and modernized automation tools and system support. 

OPM’s partnership with other Executive Branch agencies remains one of the most important components of achieving our 

strategy for continuous improvement. OPM co-chairs and participates in a number of Executive Branch working groups, including 

the Federal Investigative Standards Working Group, Quality 

Standards Working Group, and Data Standards Working Group, all 

focused on governmentwide process, quality, and standardization 

improvements. In addition, OPM will continue to work with our 

Federal, State, and local record providers to streamline collection 

methods, standardize record formats, and work to identify 

adjudicatively relevant information that will enhance the content of 

our investigations. 
10 

1The prepared statement of Mr. Sowell appears in the appendix on page 77. 

Last, OPM is engaged in transforming our suite of eight critical 

tools that we use to push investigative information. I am extremely 

proud of the contributions that OPM has made in reforming the security clearance investigative process. Through sustained leadership of this Subcommittee and our joint partnerships, we have successfully worked through and overcome huge challenges. OPM 

looks forward to improving on our successes as we focus on executing our critical executive agency responsibilities to sustain the 

momentum. 

Thank you for the opportunity to testify. I look forward to your 

questions. 

Senator AKAKA. Thank you very much, Mr. Miller. 

Mr. Sowell, please proceed with your statement. 

TESTIMONY OF CHARLES B. SOWELL,1 DEPUTY ASSISTANT DIRECTOR FOR SPECIAL SECURITY, OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE 

Mr. SOWELL. Thank you, Mr. Chairman, and thank you for the 

opportunity to discuss the progress we have made together on security clearance reform. 

I am pleased to appear beside our principal partners of reform 

who work together to ensure that improvements to timeliness, 

quality, and reciprocity are institutionalized and sustained. Director Clapper continues to give extensive time and attention to this 

effort and he recognizes that his role as Security Executive Agent 

is key to continuing the significant progress we have made in 

transforming the end-to-end security clearance process across the 

Federal Government. Clearance reform truly remains one of his top 

priorities. 

This initiative has enjoyed a unique level of bipartisan support, 

and I believe that our success is the direct reflection of that bipartisanship. We are grateful to this Subcommittee and particularly to 

you, Senator Akaka. During your tenure as Chairman, security 

clearance reform has thrived. 

Today, I would like to focus my remarks on the DNI’s efforts and 

accomplishments. As the Security Executive Agent, Director Clapper has a unique responsibility for implementing comprehensive security clearance reform. And over the past 2 years, we focused our 

efforts on institutionalizing his responsibilities in this area. 

In August 2011, we issued a policy clarification to eliminate discrepancies between intelligence community and national investigative standards which immediately improved governmentwide reciprocity. Reciprocity is important, because as this Subcommittee 

knows well, it eliminates redundancy, lessens the likelihood of errors, and saves time and taxpayer dollars. 

In March 2012, the DNI issued Security Executive Agent Directive 1 (SEAD), a first of its kind publication, which clearly outlines 

the Security Executive Agent’s authorities and responsibilities 

across the U.S. Government. SEAD 1 applies to all departments 

and agencies. The DNI also led the interagency efforts to revise the 

National Security Adjudicative Guidelines which we expect to issue 

later this year. 
11 

The DNI continues to support the PAC’s goals, including aligning 

security and suitability, improving quality, timeliness, and reciprocity. Our most mature oversight function in support of these 

goals involves tracking and reporting security clearance timeliness 

data from agencies across the government. Based on this data, in 

2009, the DNI began issuing annual letters to departments and 

agencies that were failing to meet these timeliness goals. We believe these letters reflect oversight best practices. We report the 

facts, we hold the agencies accountable, but we do so in a way that 

encourages continual improvement and explicitly recognizes 

progress. In other words, Mr. Chairman, we have taken a play out 

of this Subcommittee’s playbook. 

Over the past year, we have refined our annual letters and added 

periodic reinvestigation timeliness and backlog numbers to further 

assist the PAC in understanding agencies’ individual and collective 

performance. 

In January 2012, the DNI sent letters to 46 departments and 

agencies addressing their 2011 performance. Twenty-two agencies 

met the timeliness goals for all of 2011. Nineteen agencies met the 

goals for some part of the year. And only five agencies did not meet 

the goals and were directed to provide improvement plans. And of 

particular note, four out of the five agencies which did not meet the 

goals in 2011 actually improved their performance throughout the 

year. We found this very encouraging, because given the complexity 

of the security clearance process and the organizational challenges 

at play, even moderate improvements demonstrate a commitment 

to progress that we think bodes well. 

In addition to his oversight role, the DNI believes we must be responsive to both the emerging requirements of departments and 

agencies and the diminishing resources we all face. To that end, we 

hold quarterly Security Executive Agent Advisory Committee meetings with representatives from across the government. The meetings are rotated among the participating agencies and they serve 

as a forum to present ideas in innovative policy, technology, and 

training solutions. 

There is still work to do. We continue to focus on ensuring reciprocal acceptance of existing clearances between agencies. We have 

established a reciprocity webpage that provides education and 

awareness, a checklist of exceptions, policy references, and examples of non-reciprocity issues. Measuring reciprocity is difficult, as 

this Subcommittee knows, and despite an abundance of anecdotes, 

real data is hard to come by. 

To address this problem, we are developing a web-based form for 

individuals to submit their experience with reciprocity issues to the 

DNI. This will allow us for the first time to collect empirical data, 

perform systemic trend analysis, and assist agencies with achieving 

workable solutions. 

We have also partnered with numerous industry associations to 

address longstanding reciprocity issues. Industry is uniquely affected by reciprocity problems and they have provided key insight 

to understanding the potential impact of a variety of Security Executive Agent efforts to make improvements. 

Director Clapper is intent on creating a strong, effective Security 

Executive Agent capability for improving government operations 
12 

and efficiencies and we hope that the initiatives we have outlined 

today demonstrate that. 

Mr. Chairman, on behalf of Director Clapper, we appreciate your 

exceptional leadership and dedication to security clearance reform. 

I hope our collective efforts and successes give you reassurance 

that the time and energy you have devoted to this important national security capability have been very well spent. We look forward to the continuing partnership with our fellow agencies and 

this Subcommittee as we continue to strengthen our clearance processes in defense of the Nation. 

Senator AKAKA. Thank you very much, Mr. Sowell. 

Mr. Sowell, the absence of standardized governmentwide training 

is often cited as the reason that agencies are reluctant to immediately reciprocate a clearance. As you testified now, ODNI worked 

with OPM to develop national training standards for investigators, 

which the PAC has approved. My question to you is, how is ODNI 

working with agencies to implement the new training standards 

across the government and when can we expect full implementation? 

Mr. SOWELL. Thank you, Senator. As you mentioned, we have 

partnered with the PAC and our colleagues at OPM to develop investigator and adjudicator training standards. These will be for 

both the security and suitability populations. And as you mentioned, this will be an extremely important element of improving 

reciprocity across government. 

Where those standards are at this point is they are going 

through the review process at the DNI and OPM. The Director of 

OPM and the DNI will jointly issue the investigator training standards and then Director Berry will issue the suitability adjudicator 

training standards and Director Clapper will issue the security adjudicator standards. We expect that those standards will be issued 

before the end of summer, probably the August time frame is our 

best estimate at this point. And once those are issued, we will have 

an Implementation Working Group with representatives from 

across government to make sure that we get that right. That Working Group will form immediately after the standards are issued. 

Senator AKAKA. Thank you. 

Let me follow up with a question to Mr. Miller on that. Will you 

comment, Mr. Miller, on OPM’s role in this process and on the 

challenges implementing formalized training standards. 

Mr. MILLER. Yes. Chairman Akaka, as Mr. Sowell indicated, we 

have an interagency working group. In fact, I was the co-chair of 

the PAC Subcommittee for Training that helped develop the training standards. And the focus of the training standards was to ensure that we had standardization across the Federal Government 

relative to training for both background investigators and security 

and suitability adjudicators, and that was to lead to, obviously, reciprocity, which is the key to reform, to ensure people can move 

across the government efficiently, and we have assurances that not 

only are the folks conducting investigations doing that to a trained 

standard, but also those that are adjudicating are also adjudicating 

to a proper standard. 

The challenge will be this, getting everyone who does have training implementation requirements within their agency to comply 
13 

with the standards, which will be a role of the Executive Agents, 

both suitability and security, to ensure they meet those standards. 

Now, I can tell you personally, within OPM, we have already implemented the new Federal standards for both background investigators and suitability adjudicators and are already training our 

folks and other agencies to that standard. So we are not waiting 

for the implementation guidance to come out to make sure we move 

forward. 

Senator AKAKA. Thank you. 

Let me follow up with a question for you, Ms. McGrath, on adjudicator training. You testified that DOD initiated the Adjudicator 

Certification Program in 2010 and plans to have 90 percent of its 

adjudicators certified by this fall. Will you please elaborate on this 

program and discuss how it dovetails with the new investigator 

training standards we just discussed. 

Ms. MCGRATH. Yes, sir. Thank you. As Mr. Miller mentioned, 

DOD and the Office of Personnel Management are co-chairs of the 

Training Subcommittee that is under the PAC’s watchful eye and 

the Adjudicator Certification Program that the Department has put 

in place has served as the foundation to the national adjudicator 

program. So the linkage between the two is very solid. 

Because of the DOD’s volume and also our training facility 

through the Defense Security Service Training Academy, we have 

the ability to bring people through the training program. It is very 

important for us to ensure we have reciprocity within our own enterprise. Therefore, standardization within our own enterprise is 

extremely important so that we can have the reciprocity between 

our military departments and agencies. And so we did move out 

and, as I mentioned, the national standards are built upon the 

work that the Department started, but worked through the Training Subcommittee to ensure that we had not just the DOD requirements, but also the requirements of the Federal Government. 

And, sir, as you mentioned, we are on target to have 90 percent 

of our adjudicators complete the certification program in the September time frame and we will continue to ensure that all of them 

do meet those standards and also receive continuing education 

after they receive the certification. 

Senator AKAKA. Thank you. 

Mr. Werfel, OPM and the PAC currently track reciprocity, but 

the metrics are limited to things like the number of requested and 

rejected investigations. My question to you is are these metrics 

adequate to get a full picture of reciprocity challenges, and if not, 

what additional data will the PAC collect in the future? 

Mr. WERFEL. Mr. Chairman, thank you for the question. Clearly, 

reciprocity is central to the overall effort. I want to point out, 

though, as well, that there are broader metrics that are important 

that will show progress as we improve reciprocity generally, and 

that includes the timeliness metrics, the quality metrics, reducing 

backlogs for investigation and reinvestigation. All of that, I think, 

is relevant and a byproduct to a healthier reciprocity policy across 

the government. 

I also want to point out that there are critical steps that are underway to improve reciprocity, such as, and probably most importantly, sharing of information in an automated way across agencies 
14 

and investigations to ensure that there is seamless access that 

would enable a confidence level to occur to achieve reciprocity. And, 

obviously, all of the work that is going on to align our various policies around suitability and security clearance and standardize 

them enables, again, that confidence level to increase. 

In terms of how we measure whether all of this is resulting in 

a healthy diagnosis for how reciprocity is being used, we have a 

performance metric team in place that is evaluating different options. One of the metrics that is under development is the number 

of reciprocal actions that are occurring by quarter. I think there 

are a couple of pieces to it. 

On the one hand, you want to understand how often requests for 

reciprocity are being requested. You also want to understand at the 

back end whether those requests are being accepted and whether, 

at the end of the day, you have a situation in which someone was 

cleared through reciprocal means. 

I think if you can look at those two pieces of the life cycle together and then align them with the other broader metrics that I 

described around timeliness and quality, you are going to get to 

that point where you have a healthy and comprehensive view of 

what is going on in security clearance. But as mentioned, there is 

work to be done. These metrics are not yet fully finalized and implemented. But I think we are on the right trajectory to both define 

and implement them. 

And in the meantime, while I cannot prove it through mathematics, the availability of data in ways that it has not been available before, combined with unprecedented performance on the 

timeliness metrics that we are seeing continuous improvement on 

each quarter, give us confidence that these efforts to improve reciprocity are starting to take hold. But a good, sound metric will help 

us monitor that very closely and we are working towards that. 

Senator AKAKA. Thank you, Mr. Werfel. 

As you mentioned, in addition to tracking reciprocity, the PAC 

has established performance metrics to gauge the progress and 

quality of clearance investigations and adjudications. How is the 

PAC using the results of metrics to guide reforms? 

Mr. WERFEL. Mr. Chairman, a high-level way of thinking about 

this reform effort is there are a few key pieces to it. One is that 

we are ensuring that we have the right amount of resources dedicated to reducing the backlog and driving activity, key points in 

these processes. 

And second, in addition to making sure that the resources are 

right to attack the problem, that we are also positioning ourselves 

by making sure that our policies make sense to enable reciprocity 

and making sure that our information technology is deployed most 

effectively. And the metrics are constantly referred to and looked 

at in our PAC meetings, in the subcommittee meetings, to guide 

those efforts. 

We have talked a little bit about the oversight role that the PAC 

plays, the fact that DNI has sent letters to those agencies that are 

underperforming, the fact that OPM has done over 60 on-site visits 

to various agencies to essentially audit their work. Those decisions 

are driven by what we see in the timeliness metrics, trends, under-
15 

performance. So in that way, the entire oversight framework is 

driven by the underlying data. 

Similarly, as we debate and dialogue exactly how to structure the 

investigative standards to ensure the appropriate alignment, we 

are again looking at the numbers and what the underlying data are 

telling us in order to balance some key things between quality and 

timeliness. 

So I think you are going to hear a lot today and have heard a 

lot today about this being a model. It has the key ingredients. It 

has the dedication of resources at multiple levels, including at a 

high level. It has a commitment and a long-term commitment to 

changing the policies to make them more fluid in serving a particular objective. And then modernization and automation are driving everything that we do. 

But critical to all of that is the reliance on metrics to make sure 

that we are making smart decisions along the way. So, again, I 

think all the right ingredients are there. 

Senator AKAKA. Thank you so much. 

Mr. Dodaro, GAO has focused extensively on security clearance 

reform since it was placed on the High-Risk List in 2005 and has 

worked closely with the PAC to address performance measures for 

the quality and reciprocity of clearance investigations and adjudications. Is GAO satisfied with the PAC’s work to address performance measures? 

Mr. DODARO. I think, basically, we were satisfied enough with 

the progress that had been made to remove them from the HighRisk List last year. But, as has been pointed out by every witness 

this morning, there are still additional efforts that need to be attended to going forward. 

Principally in the reciprocity area, there need to be metrics. I 

agree with Mr. Werfel that reciprocity in the investigation and adjudication and timeliness all need to be looked at together to get 

a comprehensive picture of what is happening. 

So good progress is being made, but it needs to be sustained and 

it needs to be improved and continually enhanced going forward. 

And as long as there is a process in place, and we are going to stay 

focused on watching this evolution as it takes place, I think continued progress can be made in those areas. 

Senator AKAKA. Thank you, Mr. Dodaro. 

Mr. Sowell, in his previous testimony before the Subcommittee, 

Director Clapper noted that the Intelligence Community should be 

subject to the same quality metrics as the rest of the Federal Government. To what extent is the IC collecting data related to these 

quality metrics and what does the information show regarding the 

quality of investigations and adjudications in the IC? 

Mr. SOWELL. Thank you, Senator. As you know, the intelligence 

community’s cleared population consists of more ‘‘top secret’’ Sensitive Compartmented Information (SCI) level clearances. Those 

clearances are granted on far more detailed investigations and adjudications because of the sensitivity of the data that the people 

are given access to. 

Our data indicates that the quality of those investigations across 

the IC is consistent and very good and we are working with our 

partners at OPM and across the agencies that have independent 
16 

investigative authority. We are exploring specific metrics for the IC 

that would give us better insight into exact quality measures. 

I think it is important that anything we do in the IC is also coordinated closely with the PAC because we want to have an applesto-apples comparison as we look at quality data, timeliness data, 

reciprocity data, et cetera. 

Senator AKAKA. Thank you. 

Mr. Miller, I appreciate your focus on quality and completeness 

in addition to timeliness. I understand that DOD has implemented 

the Rapid Assessment of Incomplete Security Evaluations (RAISE), 

to flag incomplete investigative reports and compile data that can 

be shared with OPM. How does OPM plan to use the results of 

RAISE to improve the quality of its investigations? 

Mr. MILLER. Thank you, Chairman. We receive feedback from 

DOD periodically on the results of their RAISE assessments that 

are filled out by their adjudicators as they evaluate an investigation. In fact, that leadership on the part of DOD in developing 

RAISE actually pushed forward the idea of developing a Quality 

Standards Working Group, an interagency group, to assess and put 

together a standard for the Federal Government relative to investigations. RAISE, as it is being used within the Department, is now 

being looked at as being expanded as a Federal wide quality assessment tool that can be used for all investigative service providers, not just OPM, but for those that have also been granted delegation for investigation. We co-chair that working group and we 

are working towards—and again, using RAISE as the current 

standard—expanding that to have a Federal standard for that. 

So the feedback is critical. It helped actually identify some challenges we had relative to current investigative standards and ensuring that everyone was complying with standards when they conduct an investigation and this will help us in the future, as well. 

Senator AKAKA. Thank you so much. 

Mr. Werfel, in your testimony, you state that over 99 percent of 

clearance application submissions to OPM are now electronically 

completed. I commend the PAC’s efforts in leveraging technology to 

move away from the old paper-based applications to more efficient 

processes such as the use of the Electronic Questionnaires for Investigations Processing (e-QIP). Why are some agencies still using 

paper-based applications? And how does this impact the PAC’s efforts to improve governmentwide timeliness and quality standards? 

Mr. WERFEL. Thank you, Mr. Chairman. I think it is both. As it 

turns out, it is basic common sense that the automation of our 

forms are going to lead to efficiencies, and here that common sense 

can be proven with data and real-time information that demonstrates that where those agencies have moved to an electronic 

process, it is just so much more efficient, in time, in particular. 

It is not just that the transmission of the records are quicker. 

You also are more guaranteed to have a complete file because if 

you are filling it out on paper, you can leave out a question or put 

something down that is ineligible or illegible and the information 

can be transmitted to the reviewer, and then all of the sudden they 

realize they do not have certain information. They have to send it 

back. Whereas in an electronic environment, the system can make 

sure that before you have closed out and can articulate that you 
17 

have a completed file, that everything is clear and understandable, 

at least as it is programmed into the system that we have running 

for e-QIP. 

And I can go on and on and on about both central and tangential 

benefits. And we are trying to carry that message across to those 

agencies that have not yet implemented an electronic means. I 

think it is just a lot of elbow grease that is required on our behalf 

to go in and make sure that the agencies are focused on taking 

those critical steps to deploy these modernized solutions. 

I think it is pretty clear what the results are. I think it is about 

just pushing to make sure that it becomes a priority. And I think 

that is one of the reasons why the PAC has determined that the 

type of oversight that we are doing is appropriate. I work on a variety of different interagency councils across government and not all 

of those councils have deployed this technique of sending representatives from the council to a particular agency, in particular an 

under-performing agency, and to apply that type of pressure and 

accountability and technical assistance to make sure that progress 

is being made. And the work that ODNI and OPM are doing is 

having an impact and the take-up rate has increased and we expect it will increase over time. 

So, ultimately, I think it is very clear that to the extent the agencies will adopt these electronic means, their performance will improve. That is both inevitable and certain and it is proven. For us, 

it is about staying relentlessly determined in making sure that 

these very powerful tools are implemented. And I think progress is 

being made. 

We referenced the 99 percent statistic and clearly that is important progress. That does not mean that we are done, because an 

agency that is not utilizing these tools is operating in a non-efficient manner and it is our job to make sure that we end all of those 

situations across government. 

Senator AKAKA. Thank you. 

Mr. Dodaro, your statement notes that OPM still converts electronic applications to paper-based investigation files, in part because of the small number of agencies without electronic capabilities. Will you elaborate on this problem and how it should be addressed? 

Mr. DODARO. Basically, yes. The electronic applications are received and then converted into paper documents, and the real solutions to this, I believe, are a couple-fold. Number one is that some 

of the smaller agencies could benefit from the IT investments that 

have been made in the larger agencies. This was the point I was 

making earlier about leveraging existing technologies, for example, 

to use DOD’s system or some variation of it rather than try to justify an IT investment for a relatively small number of cases that 

may need to be processed for some of these smaller agencies. So 

you have to leverage technology, I think, a little bit more to help 

the smaller agencies with systems that are in place that could be 

used in their area. 

Second, OPM, as I mentioned earlier, is doing a process study of 

the efficiencies in their own process, and I believe that the study, 

if done properly, can highlight additional areas where this conversion process may not have to take place or it should not be as ex-
18 

tensive. And I think there are a lot of opportunities to gain efficiency in those processes by studying how to tackle some of the 

time lags that are a part of this process. It will have multiple benefits in terms of both improving the timeliness as well as the quality 

of the investigations because more information will be able to be 

processed in an easier manner than through the manual conversion. 

Senator AKAKA. Thank you, Mr. Dodaro. 

Mr. Miller, I understand that OPM has been engaged in a wideranging transformation of its EPIC IT system. During our last 

hearing in 2010, I asked Director Berry about costs and schedule 

concerns with this project. Would you please update us on the status of this project and how OPM intends to use these investments 

to streamline and automate the clearance process? 

Mr. MILLER. Yes, Mr. Chairman. The investment that we are 

making is critical to ensuring that we remain agile enough to handle the challenges of the future. We have eight key systems that 

we are modernizing and I would like to characterize it as that old 

Volkswagen van that we used to all drive that would always start 

no matter what the circumstances. We are operating with a system. It is old, but it has been reliable. And what we are currently 

doing is we are updating that system. We are investing from 2008 

until 2014 and so we are a good part of the way through our 

deliverables and our investment and we are seeing, in fact, increased capability. As we deliver new capability, we have seen new 

abilities to do new things with our systems. 

We are operating right now on very old software, in particular, 

and a great deal of our investment is to update and modernize 

that. We literally have to do coding, very detailed, very costly coding today where we are now incorporating either government offthe-shelf (GOTS) or commercial off-the-shelf (COTS) products that 

will advance us more rapidly and make us more responsive to the 

needs of our customers. 

So by 2014, we will have a new van, a van that will run and operate and be efficient, and we will no longer have that additional 

investment, IT investment that has been occurring between 2008 

and 2014. We will go back to our normal operations and maintenance (O&M) investment. We are on track. 

Senator AKAKA. Thank you. 

Ms. McGrath, during our last hearing on this subject, I asked 

you about the status of DOD’s new clearance IT system known as 

the Defense Information System for Security (DISS), D–I–S–S. Do 

you have updates on its capabilities, when it will be fully functional, and how DOD has budgeted for its implementation and 

maintenance? 

Ms. MCGRATH. Yes, sir. The DISS, is essentially a family of systems. There are three main pieces. One, I mentioned in my opening 

remarks, the Case Adjudication Tracking System. That does the 

case management, which is the movement of the cases and also adjudicative determinations. 

Our Joint Personnel Adjudication System (JPAS) is our legacy 

system that is the database that houses the decisions that have 

been made. That is to be replaced with a system called the Joint 

Verification System (JVS). And then to the extent that we decide 
19 

as a group to enable an automated records check capability, that 

would be the third aspect of DISS. 

The CATS piece is fully implemented across our adjudication facilities today. We are also moving toward a much more consolidated adjudicative capability across the Department. The Joint 

Verification System is targeted for implementation in 2014. The decisions that we make as a Federal group with regard to the right 

approach to automated records checks will determine the implementation of that piece should the DOD be asked to do that. 

CATS and JVS are fully funded and on track within the Department, and again, CATS being fully implemented. 

Senator AKAKA. Thank you very much. 

Mr. Sowell, national security threats can be posed by individuals 

who already have access to classified information. Timeliness reforms have focused primarily on initial security clearances. However, attention must also be paid to continuous monitoring and 

periodic reinvestigations. How is ODNI addressing these issues and 

how does it plan to improve moving forward? 

Mr. SOWELL. Thank you, Mr. Chairman. Yes, the insider threat 

is something that we are all very concerned about. As you can 

imagine, someone who does not have a clearance does not have access to the crown jewels. The people who are inside the system 

with the access to our most sensitive secrets are the populations 

that we are among the most concerned about. 

Following incidents over the past few years, we have stood up 

the National Insider Threat Task Force and that task force is looking at policy and technology and training issues that can all be 

brought to bear to address the insider threat issue. Key to addressing that issue, of course, is looking at our cleared population in a 

timely manner. 

One of the benefits of IRTPA was that it established timeliness 

goals for initial clearances, and I think the PAC leadership, in their 

wisdom, realized that you cannot just set timeliness goals for initial investigations. You also need to look at reinvestigations. So we 

do have a timeliness goal for periodic reinvestigations. 

I think our challenge is that while agencies are meeting those 

goals, there is a problem where you are only being measured when 

you submit the periodic reinvestigation through the process. So if 

you have not submitted someone for a reinvestigation, they are not 

being tracked. And so in his letters last year, Director Clapper 

started notifying agencies that we are going to be in the following 

year, so for 2012, measuring their backlog of periodic reinvestigations, and we think that this will give key insights to both the DNI 

and to the Performance Accountability Council on the extent of the 

problem and give us some indications of where we need to focus 

our efforts and attention. 

Senator AKAKA. Thank you. 

Mr. Miller, GAO recently issued a report on OPM’s investigation 

pricing structure which identified costs for OPM personnel and contract employees doing field work as primary cost drivers. Spending 

on these contracts has risen rapidly, from roughly $19 million in 

fiscal year (FY) 2005 to a peak of just under $486 million in fiscal 

year 2010. Please explain any recent efforts to evaluate OPM’s investigative workforce as well as whether its current size and com-
20 

position most efficiently use taxpayer dollars to accomplish that 

mission. 

Mr. MILLER. Yes, Mr. Chairman. We are hyper-vigilant about the 

expenditures of OPM. We are interested in full cost recovery. We 

are not profit driven. And so back in 2005 when you had tremendous backlogs and Periodic Reinvestigation (PRs) were not being 

conducted, I do not think at that time the government really recognized the cost associated with a current program. In fact, it had not 

been current since time could remember. And so when the program 

was transferred in 2005, there is a recognition that we probably 

have to increase the field investigative force to as many as 8,000 

people. Along with the backlog and the burden of clearing those 

PRs that had not been accomplished, we still had to now meet an 

Intelligence Reform and Terrorism Prevention Act requirement of 

a 40-day standard. 

So whether it is relative to a perfect storm or not, we combined 

not only a huge backlog, but we drove investigative times down. 

And we also implemented new standards during that period and 

we have seen a significant increase in the number of field work intensive investigations. As I mentioned earlier, our Top Secret (TS) 

investigative workload went up 21 percent. One ‘‘top secret’’ investigation is $4,000. A National Agency Check and Inquiries (NACI) 

investigation can range from $125 to $228. So when you see 20 percent of your workload go to the TS side, you are spending 10, 20 

times the amount of money for an investigation. 

So we believe we have a great process in place. We have competition among our contractors. In fact, this year, our contractors, due 

to recognizing the distribution of their work, began to compete 

more dramatically on fees and we saw a reduction of almost 13 percent in the cost being charged to us by our contractors, which, extrapolated out this year, could result in a $68 million savings to the 

government. 

So we have a 25 percent baseline Federal workforce, which is 

critical. We align those mostly with our DOD customers where we 

know we have consistent workload. That is a sunk cost for us. We 

are going to pay their pay and benefits. And then as work needs 

to be delved out to our contractors, we pay them by the product 

they produce. 

So we continue to work to drive our costs down. We are conducting a manpower study to drive our own resources down. In 

fact, we have reduced our own manpower footprint on the Federal 

side by about 120 personnel this year. 

Senator AKAKA. Thank you very much. 

Mr. Dodaro, as you know, I worked with Senator Carper and others to enact the Government Performance and Results Act (GPRA) 

Modernization Act, which encourages a cost-cutting approach, leadership commitment focus on management, and the use of performance metrics to achieve better results for the American people. At 

our hearing on implementation of the Act last year, you cited security clearance reform as an example of the type of progress that 

could be made using this approach. What lessons from security 

clearance reform can agencies apply to other high-risk areas, and 

what tools does the GPRA Modernization Act provide for this type 

of systemic reform? 
21 

Mr. DODARO. I think the GPRA Modernization Act provides extensive opportunities to address these type of issues. First, it enhances consultation requirements with Congress, which I think is 

pivotal. I think there is an example in personnel security clearances of Congress convening a meeting to talk about performance 

metrics, to provide input. So I think the Congressional consultation 

element of the GPRA Modernization Act is very important and a 

good lesson learned, and the application in this area is a good example of how that could happen. 

Second, it focuses a lot on cross-cutting issues. The original Act, 

as you know, in 1993, focused on an agency-by-agency strategic 

planning and performance measures. More and more issues require 

multiple agencies to work together to address those issues to 

achieve an overall outcome. The security clearance area is another 

example of where now agencies are working together and organized 

properly and setting goals that collectively need to be met on a governmentwide basis, and I think more of that needs to be done and 

I think the GPRA Modernization Act is a good example of that. 

Third, there needs to be regular reporting. The GPRA Modernization Act requires quarterly reporting of performance metrics 

on a public Web site, and I would hope that perhaps this area, the 

personnel security clearance process, can evolve to that as well, to 

be more transparent and to provide reporting requirements. One 

thing I am a little concerned about is that the timeliness reporting 

requirement for this area lapsed last year from the 2004 Act. And 

so I think there needs to be continued regular reporting in this 

area. 

Additionally, the GPRA Act focused really on quality measures 

and outcomes and I think that area needs a lot of attention. The 

initial focus here, properly so, was on timeliness. But the real bottom line is, are people getting the clearances who should be getting 

the clearances and that is a function of quality. And I would encourage OPM in their task force that they mentioned to look at the 

RAISE tool and expand it across the government, expedite their 

work in that area, because I think quality is really pivotal in this 

area, and to continually reset goals. For example, it was mentioned 

here that the timeliness goal now for reinvestments is 150 days. 

Well, that is more than double the goal for the initial clearances. 

Perhaps that goal can be driven down over time through proper application of GPRA Modernization practices. 

So those are a few of the ways that the GPRA Modernization Act 

could continue to improve the personnel security process, as well, 

as taking those lessons learned and implementing them more governmentwide in other high-risk areas. 

Finally, I would just say that we have been working with Mr. 

Werfel and Mr. Zients at OPM in the 30 areas that are currently 

on the High-Risk List to have joint meetings to talk about metrics 

and how to assess progress going forward. So we are trying to take 

the lessons learned from this particular example and trying to implement them in other high-risk areas. Ms. McGrath has been involved in the ones at DOD, as well. 

Senator AKAKA. Well, thank you very much for your responses. 

This is my final question and it is to the entire panel. What oversight or legislative actions do you believe Congress should consider 
22 

to help sustain the progress made in the security clearance process? I would like to ask Mr. Werfel to begin followed, by Ms. 

McGrath, Mr. Miller, Mr. Sowell, and then Mr. Dodaro. Mr. Werfel. 

Mr. WERFEL. Thank you, Chairman. It is a very good and important question. One of the reflections that I have is that the IRTPA 

framework worked and worked effectively. It set out a hard target 

and it required the Executive Branch to organize itself to meet that 

target, but it did not necessarily set out how the Executive Branch 

would do so. 

What we have borne out of that framework is an integrated process bringing the right Federal agencies to the table. There are clear 

lines of leadership and governance. And as we mentioned today, 

there is a good, healthy mix of accountability, performance, transparency, and a willingness to reform the processes of government 

and the technologies of government to get the job done. 

All that being said, it could be very easy, as we have seen in 

other areas of government historically, for that performance to 

lapse if the type of attention does not sustain it in this way. My 

gut tells me that the right approach from Congress’s vantage point 

is to make sure that the oversight is sustained, that the hearings 

continue. It does not actually even have to be hearings. It could be 

staff-level briefings. And those hearings and briefings need to focus 

and isolate, if possible, where any of the performance gaps are occurring because there may be a need for further legislation if either 

certain performance gaps that exist today sustain over time or if 

new ones emerge. 

But I think the overarching framework has worked very well, 

and so I think where we want to be is in a place where we are 

monitoring for particular systemic problems that may emerge, and 

to the extent we can, move quickly to close those gaps, potentially 

through legislative solutions. But we have to be in a monitoring 

mode and I would urge not to do anything that would necessarily 

change some of the guiding elements of the IRTPA framework that 

have worked so well, which combined the combination of a hard 

target with a certain amount of Executive Branch flexibility in 

order to achieve that target. 

Senator AKAKA. Thank you very much. Ms. McGrath. 

Ms. MCGRATH. Yes, sir, and I would actually echo, probably fully, 

Mr. Werfel’s comments with regard to IRTPA told us what in terms 

of setting the target but did not dictate how and it gave us the 

flexibility to establish the Performance Accountability Council and 

then drive performance through oversight of this Subcommittee, 

the Council, and then the reporting aspects. 

I do think that to ensure Congress is also informed on a regular 

basis with regard to performance, we should ensure on a very routine basis that you have those performance measures. We do collect 

them. But at this time, I do not see a need for immediate legislation, but per Mr. Werfel’s point, going forward, and as we get further into our reform effort, there is always the opportunity to come 

back and ask. So thank you. 

Senator AKAKA. Thank you. Mr. Miller. 

Mr. MILLER. Mr. Chairman, I would echo Mr. Werfel’s comments, 

as well. We recognize that through the Chairmanship of the PAC 

by OMB there has been great progress in security clearance re-
23 

form. And as we recognize challenges as they come up, the PAC 

has been aggressive in standing up appropriate subcommittees like 

we did for training, as we have for performance, and as we are 

talking about doing for record repositories to ensure that we get a 

consistent flow of information across the Federal Government in 

standardizing those records so we can obtain them and pass them 

on to those that need them. 

So I would agree that we need to be vigilant. Persistent surveillance on performance is critical. And we will report our continued 

performance through the PAC. 

Senator AKAKA. Thank you very much. Mr. Sowell. 

Mr. SOWELL. Thank you, Mr. Chairman. I agree with my colleagues. I do not see the need for additional legislation at this 

point, but clearly, continued oversight and attention is key. I think 

the combination of the Performance Accountability Council, the 

Government Accountability Office, the Security and the Suitability 

Executive Agents, and this Subcommittee, working together to 

align the security and suitability processes in every possible way, 

is where we will get the most bang for our buck. 

Senator AKAKA. Thank you very much. Mr. Dodaro. 

Mr. DODARO. Clearly, additional oversight and monitoring is important. The real question is how to do that. The first area I would 

say is in regular reporting. I think in the absence of additional legislation, given the lapsing of the timeliness reporting under the 

2004 legislation, there should be a commitment to substitute for 

that possibly an agreement by the Administration with Congress 

on what form that regular reporting will take place. It could be 

done through the GPRA Modernization Act framework support. But 

I do not think it should be left to be totally unclear or ambiguous 

about how that reporting will take place. And if there is a satisfactory solution without a legislative outcome then that is fine. 

If that solution falls short of what Congress needs to get regular 

information, it is important, and I do not think this area ought to 

be treated or subjected to lesser requirements than what the GPRA 

Modernization Act calls for now in terms of quarterly reporting, 

visibility, et cetera, and also to continue to improve the performance metrics, particularly for the quality area. I think the quality 

area is essential to ensuring that the objective of providing clearances which is to make sure that people who should not have access to National Security information do not have access to it. 

The other area I think is important is that the Performance Accountability Council has been created through Executive Order 

(EO). And while attention to this area has transcended over the 

last two Administrations, there have been slightly different tactics 

taken by the different Administrations, and I would say that would 

be an area that needs monitoring, as well. And a number of other 

areas, whether it is the Chief Financial Officer (CFO) Council, the 

Chief Information Officer (CIO) Council, the Chief Human Capital 

Officer (CHCO) Council, there is a legislative underpinning that 

provides for transition between administrations over time. So that 

is another area that I think there should be an eye kept towards 

because the current configuration has worked well. Hopefully, it 

will be continued in the future, but there is no guarantee absent 

a legislative mandate. 
24 

Senator AKAKA. Well, thank you very much. 

At this time, there are no further questions. I would like to 

thank all of the witnesses for being here today. Your responses 

have been great. It will certainly help the Subcommittee and all of 

us continue the progress that has been made at this time. 

The security clearance process is a model for cross-cutting systemic reform. The Performance Accountability Council, working together with GAO and Congress, has made great strides and has 

created a framework for continued improvement. Ongoing leadership commitment and oversight are still needed if our accomplishments are to last into the future. 

The hearing record will be open for one week for any additional 

statements or questions from other Members of the Subcommittee. 

And again, I want to thank all of you for all of your work. You 

have been tremendous in bringing the progress about and I want 

to wish you well in your work. 

The hearing is adjourned. 

[Whereupon, at 4:02 p.m., the Subcommittee was adjourned.] 
(25) 

A P P E N D I X 

FOR IMMEDIATE RELEASE: June 21. 2012 

Contact: Jesse Broder Van Dyke 202-224-7045 

k':-'"-t:~~j~~I~~~{I.)CI1(i_~~ 

STATEMENT OF CHAIRMAN DANIEL K. AKAKA 

Security C1eurunce Re/iJrm: Sustaining Progress /iJr the Future 

Hearing 

Subcommittee on Oversight of Government Management, 

the Federal Workforce, and the District of Columbia, 

Senate Committee on Homeland Security and Governmental Affairs 

Aloha. I want to welcome our "itnesses to today's hearing: Security Clearance Re/imn: Sustaining 

Progressfi)/" the Future. 

In 2005. the Government Accountability Office (GAO) placed the personnel security clearance process 

on its lligh-Risk List due. in part. to a massive backlog of applications and insufficient quality 

standards. This is the Subcommittee's eighth hearing on the security clearance process since that time. 

In addition to GAO's and the Suhcommittee's oversight. the administration has placed long-terrn. highlevel focus on reforming the process. I am pleased to say that last year, the security clearance 

was removed from GAO's High-Risk List. The application backlog has been climinated. and 

rcquircments in the 2004 Intelligence Reform and Terrorism Prevention Act have been met and 

exceeded. Today. initial investigations take an average of 44 days to complete. compared to a 

staggering 189 days in 2005. 

Investigation quality improvements were another key aspect of removing Ihe high-risk designation. In 

multiple reports. GAO had found that clearances were granted based on incomplete investigation files. 

Moreover. there was no way to evaluate the quality of security clearance determinations to make sure 

security threats were consistently weeded out. Lapses in quality posed a national security risk. 

rhe Performance Accountability Council (PAC) has worked together to address all aspects of 

investigation and adjudication quality. The PAC has updated the security clearance application. 

improved interview techniques. and created quality metrics. Its members are working to standardize 

investigator training and to develop government-wide adjudication guidelines. 

Despite considerable progress. remain. Continued oversight and accountability are needed to 

continue progress and momentum Reciprocity continues to be an issue. In our 20 I 0 

hearing. I together to accept clearances from other agencies. This allo"5 critical 

national positions 10 be tilled with the right people 1110re quickly. 
26 

Although progress has been made on this issue. establishing more uniform training. investigation. and 

suitability standards \yould increase trust bet\Veen agencies and promote reciprocity. Additional 

information technology improvements also arc needed to support information-sharing and case 

management. Without these investments. further improvements in timeliness and reciprocity will be 

difficult to achieve. 

This will be my last hearing on the security clearance process before I retire. Congressional oversight 

and sustained focus by the Executive Branch have produced a more efficient and functional security 

clearance process. I am proud of what we have accomplished together and hope that our work will serve 

as a model to address other high-risk arcas in the federal government. 

I will continue to monitor this issue during my remaining time in the Senate. and I hope that future 

Members of this Subcommittee continue to focus on this critical issue. I look forward to hcaring from 

our witnesses on how they plan to build on this legacy and ensure thc continucd sllccess of the security 

clearance process. 

-E'\D-
27 

GAO 

For RE'lease on Delivery 

Expected al2:30 p.m. EDT 'Thursday, June 21, 2012 

GAO-12-815T 

United States Government Acconntability Office 

Testimony 

Before the Subcommittee on Oversight of Government 

Management, the Federal Workforce, and the District of 

Columbia, Committee on Homeland Security and 

Governmental Affairs, U. S. Senate 

PERSONNEL SECURITY 

CLEARANCES 

Continuing Leadership and 

Attention Can Enhance 

Momentum Gained from 

Reform Effort 

Statement of Gene L. Dodaro 

Comptroller General of the United States 

GAO 

Accountability'" Integrity * Reliability 
28 

Highlights ofGA0-12·815T, a testimony 

before the Subcommittee on Oversight of 

Govemment Management. the Federal 

Work.force, and the District of Columbia, 

Committee on Homeland Security and 

Govemmental Affairs, U,S. Senate 

Why GAO Did This Study 

As of October 2010, the Office of the 

Director of National Intelligence 

reported that 3.9 million federal 

employees (military and civilians) and 

contractors hold security clearances, 

DOD comprises the vast majority of 

government security clearances. 

Longstanding backlogs and delays in 

the security clearance process led 

GAO to place the DOD's Personnel 

Security Clearance Program on its 

high~risk list in 2005. Delays in issuing 

clearances can result in millions of 

dollars of additional cost to the federal 

government and could pose a national 

security risk. DOD and others have 

taken steps to address these issues 

and additional concerns with clearance 

documentation used to determine 

eligibility for a clearance, As a result in 

2011, GAO removed the program from 

its high-risk list. 

This testimony addresses (1) the key 

actions that led GAO to remove DOD's 

security clearance program from its 

high-risk list and (2) the additional 

actions that can enhance the security 

clearance refonn efforts, This 

statement is based on prior GAO 

reports and testimonies on DOD's 

personnel security clearance program 

and govemmentwide suitability and 

security clearance reform efforts. 

View GAO·12~815T. For more information, 

contact Brenda S. FarreJl at (202)512~3604 or 

farreflb@gao gov, 

pt!l"MfJW4t'F 

PERSONNEL SECURITY CLEARANCES 

Continuing Leadership and Attention Can Enhance 

Momentum Gained from Reform Effort 

What GAO Found 

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

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

Congress and executive agency leadership, took actions that resulted in 

significant progress toward improving the processing of security clearances. 

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

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

helped focus attention and sustain momentum of the governmentwide reform 

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

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

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

and Security Clearance Performance Accountability Council (Performance 

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

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

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

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

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

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

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

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

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

completeness of investigation documentation and agencies' adjudication process 

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

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

that assess the tImeliness and quality of investigations, adjudications, reCiprocity 

and automation of security clearances. 

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

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

enhance the security clearance reform efforts of executive branch agencies and 

the Performance Accountability Council: 

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

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

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

enable the executive branch to demonstrate progress in quality 

improvements and contribute to greater visibility over the clearance process, 

Seek opportunities to enhance efficiencies and manage costs related to the 

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

funding requirements for the security clearance process is critical for the 

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

venue to facilitate the identification of efficiencies in areas including 

information technOlogy and investigation and adjudication case management 

processes. 

Create a sound requirements process for determining which positions require 

clearances and level of clearances. A sound requirements determination 

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

necessary by ensuring that clearances are only requested for positions when 

needed and that the appropnate clearance level is requested. 

_____________ United States Government Accountability Office 
29 

Chairman Akaka, Ranking Member Johnson, and Members of the 

Subcommittee: 

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

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

list. 1 As you know, we maintain a program to focus attention on 

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

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

for transformation to address economy, efficiency, or effectiveness 

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

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

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

removed from the list because Significant progress was made to address 

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

including those in response to our recommendations, result in Significant 

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

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

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

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

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

additional actions that can enhance the governmentwide personnel 

security clearance reform efforts. 

Personnel security clearances allow government and industry personnel 

to gain access to classified information that, through unauthorized 

disclosure can in some cases cause exceptionally grave damage to 

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

classified documents posted to the Internet related to the wars in 

Afghanistan and Iraq are examples of the inherent risks involved when 

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

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

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

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

approved personnel security clearances for approximately 630,000 

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

Intelligence reported that there were approXimately 3.9 million federal 

government and contractor employees who held a security clearance. 

GAO, High-Risk Senes An Update, (WaShington, D.C February 2007) 

Page 1 GAO·12-81ST 
30 

DOD accounts for the vast majority of all initial personnel security 

clearances, making it a formidable challenge to those responsible for 

deciding who should be granted a clearance. 

Multiple executive-branch agencies are responsible for different phases in 

the federal government's personnel security clearance process. With 

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

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

information and must apply for a security clearance and undergo an 

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

conducts these investigations for DOD. OPM investigators-often 

contractors-use federal investigative standards and OPM internal 

guidance as criteria for collecting background information on applicants. 

Federal guidelines require that DOD adjudicators use the information 

contained in the resulting investigative reports to determine whether an 

applicant is eligible for a personnel security clearance. 

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

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

that reportedly supplies about 90 percent of all federal clearance 

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

clearances by DOD adjudicators even though required data were rnissing 

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

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

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

period the executive branch initiated actions to reform the 

governmentwide security clearance process. 

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

personnel security clearance program and governmentwide suitability and 

security clearance reform efforts.2 Our reports and testimonies were 

conducted in accordance with generally accepted government auditing 

standards. 

2See related GAO products at the end of thiS statement More Information on our scope 

and methodology IS incfuded in each issued report 

Page 2 
31 

Leadership 

Commitment, 

Improved Timeliness, 

and Development of 

Metrics Were Key to 

Removal of DOD's 

Security Clearance 

Program from GAO's 

High-Risk List 

Top Leadership 

Demonstrated 

Commitment and 

Collaboration in 

Reforming Security 

Clearance Process 

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

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

agency leadership, took actions that resulted in Significant progress 

toward resolving problems we identified with the security clearance 

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

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

improving timeliness and the development of tools and metrics to assess 

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

congressional oversight and the committed leadership of the Suitability 

and Security Clearance Performance Accountability Council 

(Performance Accountability Council)' -which has been responsible for 

overseeing security clearance reform efforts since 2008-greatly 

contributed to the progress of DOD and the governmentwide security 

clearance reform. 4 

Leadership in Congress and the executive branch demonstrated 

commitment to reforming the security clearance process to address 

longstanding problems associated with the personnel security clearance 

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

to organizational transformation. 5 Specifically, leadership must set the 

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

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

events related to the Suitability and Personnel Security Clearance Reform 

Effort. 

3 The Performance Accountablhty Council is comprised of the DIrector of National 

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

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

authority to designate officials from addit!onal agencies to serve as members. The current 

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

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

Federal Bureau of Investigation 

4 Determmations Of sUltablhty for government employment in positions in the competitive 

service and for career appointment in the Senior Execut!ve Service Include consideration 

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

or efficiency of their service 

5 GAO. Personnel Security Clearances. Preliminary Observations on Joint Reform Efforts 

to Improve the Govemmentwide Clearance Eligibility Process, 

(Washington, 0 C. July 30, 2008). 

Page 3 GAO·12·815T 
32 

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

May 31, 2010 

The Performance Accountability Council deVelops quality 

measures that It beheves will Identify specific quantifiable 

targets li'1ked to goals that are Intended to be measured 

objec1ively and ultimately gauge progress and assess the 

quality or the personnel security clearance process I 

January 2005 

GAO places 

DOD's clearance March 17,2009 

I 

program 0'1 Its 

I high-tlsk list +~:;~~~~~:1~~11l 

O be 17 

'

M'I I N b 2005 ~- I Enterprise I Janus'" 2011 

Intelligence Reff?rm .1 OHlee o! Managema.nt and The JOint Reform Team Technology Stra:egy GAO removes 

ecem r ,"""" I I ovem er """",ember 18, 2008 Inlormation ' 7 

and Terrons~ )1 Budget Issues a plan for Issues a report outllnhg 10 support the DOD's clearance 

preven~~;c::: I! ~~:;~~~~ ~~~s;~nty reform )~~:~~I:~~ ~~~~~~g ~;~~~ and I ~~~~:~~ i~lm Its 

IL~2~004~~~~1~12°O~5~~~~~~'~LI'2~OOOL.~~.~~."I'L2~OO~7~n~~~~"_~I'~C~~fln~n~n~I~I~2°O~9~~""~1~20~1O~~~~~,~II:!yi~20~'~'~~~I February 2005 ; June 27, 2005 Aprll3O, 2008 : June 30, 2008 I February 2011 

DOD transfers 

ItS background 

investigation 

function to OPM 

! Executive Order 13381 assigns vanous The JOint: Executive O'der 13467 i Exp'ration ollhe 

'I ,"".ctlons to the. Director of the. Ollies of Aelorrn Team I establishes the Per'ormance 12004 Intelligence 

Management and Budget to help ensure Issues a rep.ort I Accountability CounCil to drive Reform and 

that agency clearance functions are on leformlng implementation of Ine reform Terrorism 

i umform, centralized, effiCient, effective, the secunty cHort and designated the Office Prevention Act's 

I timely. and reciprocal clearance and 01 Management and Budget's timeliness reporling 

SUitability Deputy Director fot i requirements 

June 25, 2007 process Managemerl as Chair 

The Jam! Reform Team is formed to develop a plan for October 7, 2010 

intei!'gerce 

AuthOrization Act for 

Fiscal Year 201 0 

enacted. requlrhg 

'eportsby Ihe 

President on meeting 

security clearance relormobject,ves 

clearance reform, inc'udlng research priorities and an 

information lechoology strategy, to achieve lATPA goals February 16,2010 

The Performance Accountability CounCil Issues 

a strategiC framework to articulate the goals Of 

the security and SUitability process relorm 

tr Congressional Oversight Hearing 

Congressional Leadership 

Soun::e:GAOana'ys>s 

Congressional legislation and oversight has helped focus attention and 

sustain momentum to improve the processing of security clearances not 

only for DOD but governmenlwide" The Intelligence Reform and 

Terrorism Prevention Act of 2004 (IRTPA)' established, among other 

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

previously identified best practices for agencies to successfully transform 

L. No 108-458.118 Stat 3638 (2004) 

Page 4 GAO·12·815T 
33 

their cultures including among other things, setting implementation goals 

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

IRTPA established an interim objective to be met by December 2006 

under which DOD and other agencies that adjudicate security clearances 

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

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

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

which, to the ex1ent practical. at least 90 percent of decisions are made 

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

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

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

preceding year toward meeting IRTPA's objectives for security 

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

investigations and adjudications-the decision as to whether an individual 

should be granted eligibility for a clearance. 

Congressional oversight through hearings held by this Subcommittee 

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

2010, congressional committees held more than 14 hearings on security 

clearance reform, with 7 held by this Subcommittee' This 

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

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

address our concerns about the completeness and quality of 

investigations and adjudications. Many federal program efforts, including 

those related to personnel security, generally require the effective 

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

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

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

DOD-along with GAO, met with this Subcommittee's Chairman and 

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

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

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

the Department of Homeland Security and Other Federal Agencies, 

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

to Assist Mergers and Organlzalional TransformatIons. Gf- ()-22,~S69 (Washington, D.C 

July 2, 2003) 

8 GAO has testified on secunty clearance refOffTl before this committee as well as the (1) 

Subcommittee on Intelligence Commumty Management, House Permanent Select 

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

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

and (3) SubcommIttee on Readiness, House Committee on Armed Services 

Page 5 GAO~12-815T 
34 

Exeeutive Branch Leadership 

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

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

Akaka containing a matrix with 15 metrics for assessing the timeliness 

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

acceptance of a background investigation or clearance detenmination 

completed by any authorized investigative or adjudicative agency), and 

automation. 9 The development of these metrics played a key role in 

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

from the high-risk list. 

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

Government Performance and Results Act (GPRA) could play in 

identifying and fostering improved coordination across related federal 

program efforts. The GPRA Modernization Act of 2010 (GPRAMA) 10 calls 

for a more coordinated and crosscutting approach to achieve meaningful 

results. '1 GPRAMA provides an opportunity for agencies to collect and 

report more timely and useful performance information on crosscutting 

programs. This performance information can play an important role in 

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

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

challenges facing the government. 12 DOD's personnel security clearance 

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

Congress has used agency performance information in its decision 

making. 

In addition to congressional leadership, multiple administrations, DOD. 

and key executive agencies demonstrated a commitment and vision to 

reform the security clearance process. Specifically, after we initially 

9 We participated in legISlative and executive branch discuSSions on development of these 

metrics. However, given the need for GAO to remain lndependent In carrying out its 

auditing responsibilities of the executIVe branch, decisions related to performance 

measures and their effective implementatron are fundamentally an executive branch 

management responsibility. 

10pub L No. 111-352. 124 Stat 3886 

Performance and Resuits Act of 1993 

GPRAMA amended the Government 

No 103-62,107 Stat. 285 (1993). 

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

Important OpportunitIes to Address Government Challenges, G.:'.,G-'· -:;" -:'-; (Washington. 

D C .. May 10, 2011) 

12 GAO, Managing far Results' Opportunities for Congress to Address Government 

Perfarmancelssues, -::;,.1..0-:2-2~2R (Washington, D C Dec. 9. 2011) 

Page G 
35 

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

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

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

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

security clearance process governmenlwide. 13 Specifically, they tasked 

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

IRTPA timeliness goals and improve the processes related to granting 

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

a reform of the security clearance program and subsequently issued an 

executive order establishing the Performance Accountability Council. 15 

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

leading the implementation of reform, including aligning security and 

suitability processes, holding agencies accountable for implementation, 

and establishing goals and metrics for progress. 

DOD worked with the Joint Reform Team and the Performance 

Accountability Council to develop a corrective action plan to improve 

timeliness and demonstrate progress toward reforming the security 

clearance process. For example, 

DOD's leadership, in conjunction with the Joint Reform Team, 

developed a plan for reform that continuously evolved to incorporate 

13 In June 2007, the Director of NationallntelJ!gence and Under Secretary of Defense for 

Intelligence through a memorandum of agreement established The Joint SecurIty Process 

Reform Team. 

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

Accountability CounCil by providing progress reports, recommending research pnoritles, 

and overseeing the development and implementation of an information technology 

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

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

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

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

sophisticated electronic application, a more flexible Invest!gation process, and the 

establishment of ongOIng evaluat!on procedures between formal clearance Investigations 

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

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

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

Reform Team IS pursuing an approach that leverages eXisting systems and capabilities, 

where applicable, and developing new tools where necessary 

15 Exec Order No 13467, Reforming Processes Refated to Suitability for Government 

Empfoyment Fitness for Contractor Employees. and Eligibility for Access to Cfassified 

National Secunty Information (June 30, 2008). 

Page 7 GAO·12·31ST 
36 

new goals and address identified issues. To communicate these 

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

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

the security clearance process, including the use of a more 

sophisticated electronic application, a more flexible investigation 

process, and the establishment of ongoing evaluation procedures 

between formal clearance investigations. The report was updated in 

December 2008 to include an outline of reform progress and further 

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

Information Technology Strategy for the security clearance and 

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

DOD worked with the Performance Accountability Council to issue a 

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

President. The strategic framework identified key governmentwide 

reform goals and identified the root causes for timeliness delays and 

delays to agencies honoring reciprocity. It also set forth a 

governrnentwide mission, performance measures, a communications 

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

of security clearance investigations and adjudications. DOD continues 

to work with the Performance Accountability Council to sustain 

clearance reform efforts and enhance transparency and accountability 

through annual reporting to Congress. \6 

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

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

issued formal guidance clarifying if and under what circumstances 

adjudicators can adjudicate incomplete investigative reports-such as 

missing information relevant to residences, employment, or education. 

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

when adjudicators may use incomplete investigative reports as the 

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

the Under Secretary of Defense for Intelligence issued guidance on 

adjudication standards that outline the minimum documentation 

requirements adjudicators must adhere to when documenting 

personnel security clearance determinations for cases with potentially 

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

16 Annual reports were reqUIred under lRTPA through 2011. Section 367 of the 

Intelligence Authorization Act for Fiscal Year 2010, PUb. L No. 111~25g (2010), 

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

Act of 1947 (50 U.S.C. § 415a-10) 

Page 8 
37 

DOD Developed 

Assessment Tools and 

Performance Metrics and 

Improved Timeliness to 

Demonstrate Progress 

Defense for Intelligence issued additional guidance that clarifies when 

adjudicators may use incomplete investigative reports as the basis for 

granting clearances. This guidance provides standards that can be 

used for the sufficient explanation of incomplete investigative reports. 

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

Performance Accountability Directorate within the Directorate of 

Security to provide oversight and accountability for the DOD Central 

Adjudication Facilities that process DOD adjudicative decisions. 

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

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

demonstrate its progress in having implemented corrective measures. 

Longstanding backlogs and delays in the clearance process led to our 

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

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

time for DOD to determine clearance eligibility for industry personnel 

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

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

350,000 cases exceeding established timeframes for determining 

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

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

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

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

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

Delays in Determining Security Clearance Eligibiflfy for Industry Personnel. GA:J-:)4-2:::2i 

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

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

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

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

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

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

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

complete. We also found that the application~submissjon phase averaged 111 days for 

mdustry personnel seekmg initial top secret clearances, but the government goal is 14 

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

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

for the 2,259 mdustry personnel who were granted clearance elig!bllity in January and 

February 2006. GAO, High-Risk Series. An Update, 3AO-C'-3;~ (Washington, D.C .. 

January 2007). In our 2009 high-risk update, GAO~:;9~27-. we noted that DOD made 

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

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

year 2008 took an average of 87 days 

Page 9 GAO-12-815T 
38 

personnel and met the 60-day statutory timeliness objective for 

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

DOD completed 90 percent of initial clearances for industry personnel in 

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

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

average processing time for industry personnel was over a year. 

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

but also incomplete documentation of investigations and adjudications. 

We reported on missing documentation in investigative reports prepared 

by OPM that DOD adjudicators had used to make clearance eligibility 

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

investigative reports provided to DOD in July 2008 were missing required 

documentation, which in most cases pertained to residences, 

employment, and education. DOD adjudicators granted clearance 

eligibility without requesting missing investigative information or fully 

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

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

things, develop and report metrics on completeness and other measures 

of quality for investigations and adjudications that address the 

effectiveness of the new procedures. DOD agreed and implemented our 

recommendations regarding adjudication. OPM neither concurred nor 

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

has taken steps to develop metrics. 

Subsequently, DOD developed two quality tools to evaluate 

completeness of documentation used to determine clearance eligibility. 

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

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

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

Security Executive Agent of the Performance Accountability Council, will 

arbitrate any potential disagreements between OPM and DOD and clarify 

policy questions. DOD deployed RAISE to four Central Adjudication 

Facilities from July to October 2010 and planned to complete deployment 

to the remaining Central Adjudication Facilities by calendar year 2011. 

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

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

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

Page 10 GAO·12·815T 
39 

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

Review of Adjudication Documentation Accuracy and Rationales 

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

the Under Secretary of Defense for Intelligence directed DOD Central 

Adjudication Facilities to provide adjudication case records to the Defense 

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

department plans to use results of the RADAR assessments to monitor 

Central Adjudication Facilities' compliance with documentation policies, 

communicate performance to the Central Adjudication Facilities, identify 

potential weaknesses and training needs, increase compliance, and 

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

RADAR and began its implementation for the Army, Defense Industrial 

Security Clearance Office, and Navy Central Adjudication Facilities in 

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

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

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

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

the quality of the personnel security clearance process< These metrics 

represented positive developments that could contribute to greater 

visibility over the clearance process< 

Having assessment tools and performance metrics in place is a critical 

initial step toward instituting a program to monitor and independently 

validate the effectiveness and sustainability of corrective measures< The 

combination of congressional reporting requirements, the strategic 

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

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

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

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

momentum to reach the final goaL 

Page 11 GAO~12~815T 
40 

Continuing Executive 

Branch Leadership 

and Management 

Attention May 

Enhance the Security 

Clearance Reform 

Efforts 

Implementing, Monitoring, 

and Updating OutcomeFocused Performance 

Measures 

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

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

clearance reform extends beyond DOD throughout the executive branch. 

This is evidenced by the oversight structure. through the Performance 

Accountability Council, and broad executive branch participation in the 

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

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

such as continuing to monitor and update outcome-focused performance 

measures, seeking opportunities to enhance efficiency and managing 

costs, and ensuring a strong requirements determination process, may 

enhance the security clearance reform effort. 21 

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

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

DOD's adjudications through the Performance Accountability Council. We 

view the development of quality metrics as a positive step towards 

creating greater visibility over the quality of the clearance process and 

identifying specific quantifiable targets linked to goals that can be 

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

metrics to gauge progress toward improvements. Further, the 

development of performance measures related to the security clearance 

process by the Performance Accountability Council aligns with our 

previous recommendation to develop outcome-focused performance 

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

have also previously reported on the importance of continually assessing 

and evaluating programs as a good business practice, including 

evaluating metrics to help ensure that they are effective and updated 

when necessary." As a result, it is important to sustain the momentum of 

the reform and that DOD and OPM complete implementation of the 

GAO, Personnel Clearances Key Factors for Reforming the Security Clearance 

Process, 8,£'0 <)8-7751 (Washington. 0 C. May 22, 2008) 

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

GUide Implementation of the Reformed Clearance Process, G.,D..:::'~:::9~L88 (Washington, 

D.C .. May 19, 2009) 

23 GAO, Standards for Internal Control in the Federal Government, 

(Washington, D.C.: November 1999) 

Page 12 GAO·12--815T 
41 

quality tools and metrics so that the executive branch can demonstrate 

progress in improving the quality of investigations and adjudications. 

Leaders of the reform effort have consistently stated that implementation 

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

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

Performance Accountability Council quality metrics were developed 

subsequent to the issuance of the 2010 Strategic Framework, which 

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

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

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

May 31, 2010 memorandum in which the Performance Accountability 

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

reexamined for continuous improvement. Moreover, according to DOD, 

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

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

quality, it is not being used by other executive branch agenciesincluding OPM, which conducts the investigations and would be the 

appropriate agency to take actions to improve investigation qualityalthough the Joint Reform Team is considering using it in the future. 

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

demonstrate progress in improving quality. 

Emphasis on quality in clearance processes should promote positive 

outcomes, including more reciprocity among agencies in accepting each 

others' clearances. Building quality throughout clearance processes is 

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

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

part to the requirements and objectives established in IRTPA regarding 

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

repeatedly called for more emphasis on quality. 

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

key measurements as to the timeliness of initial security clearances in 

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

those reports to include the periods of time required for conducting 

investigations, adjudicating cases, and granting clearances. IRTPA 

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

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

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

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

clearances and excluded the slowest 10 percent. We previously reported 

that full visibility was limited by the absence of comprehensive reporting 

Page 13 GAO·12·815T 
42 

of initial clearance decisions timeliness. 24 Consistent with our 

recommendation, the executive branch began reporting on the remaining 

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

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

year. More recently, in 2010, the Intelligence Authorization Act of 201 0 

established a new requirement" that the President annually report the 

total amount of time it takes to process certain security clearance 

determinations for the previous fiscal year for each element of the 

Intelligence Community. 26 

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

annual reports from the President to Congress that include the total 

number of active security clearances throughout the United States 

government, to include both government employees and contractors. Its 

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

the Intelligence Community. Unlike the IRTPA reporting requirement, the 

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

Intelligence Authorization Act requires two additional one-time reports: 

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

adjudication quality, and second, a report to the congressional 

intelligence committees by the Inspector General of the Intelligence 

Community on reciprocity. The report containing metrics for adjudication 

quality summarizes prior information on developed tools and performance 

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

implementation or update of the performance measures that were 

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

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

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

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

National Geospatial-Intelhgence Agency, National Reconnaissance Office, Defense 

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

Force Intelligence (Air Force Intelligence, Survelf!ance, and Reconnaissance). Office of 

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

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

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

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

Agency (Office of Natlona! Security Intelligence), U,S, Coast Guard (Inte!l1gence and 

Cnmlnallnvestigations). and Department of Energy (Office of Intelligence and 

Counterinte!ligence) 

Page 14 GAO·12·815T 
43 

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

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

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

was enacted on Oct 7, 2010. 

The Intelligence Authorization Act of 201 0 reporting requirement on 

reciprocity-an agency's acceptance of a background investigation or 

clearance determination completed by any authorized investigative or 

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

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

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

metrics to comprehensively track when and why reciprocity is granted or 

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

previously granted security clearances. 27 We found that agencies do not 

consistently document the additional steps they have taken prior to 

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

documentation, the Department of Energy and the Department of the 

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

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

previously granted security clearance. Consequently, there is no 

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

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

In addition, agencies do not consistently and comprehensively track the 

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

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

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

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

Similarly, the metrics proposed by the Performance Accountability 

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

honored. For example, metrics proposed by the Performance 

Accountability Council, such as the number of duplicate requests for 

investigations, percentage of applications submitted electronically, 

number of electronic applications submitted by applicants but rejected by 

OPM as unacceptable because of missing information or forms, and 

percentage of fingerprint submissions determined to be "un classifiable" by 

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

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

Governmentwlde Security Clearance Process, GAC-~ ~-222- (Washington, D.C Dec. 1, 

2010) 

Page 15 GAO·12·815T 
44 

Enhancing Efficiencies 

and Managing Costs 

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

Without comprehensive. standardized metrics to track reciprocity, and 

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

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

previously granted security clearances. 

To further improve governmentwide reciprocity, in 2010 we recommended 

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

the Performance Accountability Council, develop comprehensive metrics 

to track reciprocity and then report the findings from the expanded 

tracking to Congress'" OMB generally concurred with our 

recommendation, stating that the Performance Accountability Council is 

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

on security clearance performance metrics, the executive branch is 

making progress toward developing metrics to track reciprocity 

specifically with the intelligence community agencies.29 We are 

encouraged by the Performance Accountability Council'S development of 

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

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

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

effectiveness assessed. 

Our previous work has highlighted the importance of the executive branch 

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

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

current and future reform efforts was the long-term funding 

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

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

or where funding will come from. 31 Furthermore, the reports did not 

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

but Continued Oversight Is Needed to Sustain Momentum, (Washington, 

O.C November 19. 2010) 

29 Oftke of the DIrector of National Intelligence, 2011 Report on Metncs for Security 

Clearance Adjudication Quality (January 17. 2012) 

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

Informed Congressionaf Oversight. G.A,C-J8~350 (Washington, 0 C .. February 13, 2008) 

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

GUide Implementation of the Reformed Clearance Process. 8AC-C9-";'88 (Washington, 

D.C .. May 19. 2009). 

Page 16 
45 

estimate potential cost savings resulting from the streamlined process. At 

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

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

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

issue a strategic framework that contained the long-term funding 

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

2010, the Performance Accountability Council issued a strategic 

framework that responded to our recommendation: however, that 

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

and OPM would cover costs for major information technology 

acquisitions. 

As reform leaders, through the Performance Accountability Council, 

consider changes to the current clearance processes, they should ensure 

that Congress is provided with the long-term funding requirements 

necessary to implement any such reforms. Those funding requirements to 

implement changes to security clearance processes are necessary to 

enable the executive branch to compare and prioritize alternative 

proposals for reforming the clearance processes. For example, DOD 

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

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

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

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

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

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

for decision-makers to compare and prioritize alternative proposals for 

completing the transformation of the security clearance process. Without 

information on longer-term funding requirements necessary to implement 

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

appropriations requirements. We most recently reported on two areas of 

opportunity for which the executive branch may be able to identify 

efficiencies: information technology and investigation and adjudication 

case management and processes.32 

32 GAO, Background Investigations· The Office of Personnef Management Needs to 

Improve Transparency of Its Pricing and Seek Cost Savings, 3,':'8- 12-" 9- (Washington, 

D.C .. Feb. 2012) 

Page 17 GAO-12-815T 
46 

Information Technology Is a 

PIimary Cost Driver in the 

SecuIity Clearance Process 

In February 2012, we reported that information technology investments 

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

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

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

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

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

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

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

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

Management and Budget testified that OPM now receives over 98 

percent of investigation applications electronically, yet we observed that it 

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

converts electronically submitted applications to paper. OPM officials 

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

of their customer agencies do not have electronic capabilities. 

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

As a result. OPM may be simultaneously investing in process 

streamlining technology while maintaining a less-efficient and duplicative 

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

identify process efficiencies, including its use of information technology to 

complete investigations. which could lead to cost savings within its 

background investigation processes. OPM concurred with our 

recommendation and commented that these actions also reinforce a 

Federal Investigative Services priority and that the agency will continue to 

map its process to achieve maximum process efficiencies and identify 

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

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

lead to cost savings within its background investigation process. For 

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

identifying time savings and efficiencies for future Federal Investigative 

Services' business processes which will conclude by December 2013. 

33 3AG_'2_-S7 

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

operation and mamtenance of OPM's informatton technology for processing background 

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

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

effort, known as EPIC modernization 

Page 18 GAO~12·815T 
47 

Case Management and 

Adjudication Process 

Efficiencies Could 

Reduce Duplication 

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

duplication, overlap and fragmentation, we reported that multiple 

agencies have invested in or are beginning to invest in potentially 

duplicative, electronic case management and adjudication systems 

despite governmentwide reform effort goals that agencies leverage 

existing technologies to reduce duplication and enhance reciprocity,35 

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

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

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

efficiencies with case management and an electronic adjudication module 

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

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

observed that the Case Adjudication Tracking System could easily be 

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

share the technology with interested entities across the federal 

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

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

officials, the Social Security Administration is also considering adopting 

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

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

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

suitability and security clearance process, agencies have transitioned or 

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

may not be leveraging adjudication technologies in place at other 

executive branch agencies to minimize duplication. 

Five other agencies are also developing or seeking funds to develop 

systems with similar capabilities. 36 With multiple agencies developing 

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

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

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

GAO, 2012 Annual Report. Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue. GA'J-' 2-3L2S;::' (Washington, 

D.C .. Feb 28,2012). 

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

of DOD. 

Page 19 GAO-12-815T 
48 

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

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

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

per year. 

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

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

electronic case-management system that is synchronized with its 

governmentwide background investigations system that would be 

available for their customer agencies to purchase. OPM released a 

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

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

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

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

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

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

other options that would allow customer agencies access to their 

electronic case-management system without the need to make an 

expensive initial investment. Additionally, OPM officials said that their 

effort is intended to promote process efficiency by further integrating OPM 

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

customer agencies. including DOD, which makes up approximately 75 

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

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

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

operating costs, which could affect investigation prices. 

The investment in electronic case-management systems aligns with the 

reform effort's goal to automate information technology capabilities to 

improve the timeliness, efficiency, and quality of existing security 

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

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

achieve cost savings through leveraging adjudication technologies in 

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

Information Technology Strategy, the Joint Reform Team stated that 

agencies will leverage existing systems to reduce duplication and 

enhance reciprocity, Moreover, the Performance Accountability Council is 

positioned to promote coordination and standardization related to the 

suitability and security clearance process through issuing guidance to the 

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

its mission statement, but this framework lacks specificity regarding how 

agencies might achieve costs savings. Without specific guidance, the 

Page 20 GAO·12-81$T 
49 

A Requirements 

Process for Determining 

Required Clearances and 

Level of Clearances May 

Reduce Costs 

opportunities to minimize duplication and achieve cost savings may be 

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

Performance Accountability Council expand and specify reform-related 

guidance to help ensure that reform stakeholders identify opportunities for 

cost savings, such as preventing duplication in the development of 

electronic case management.OMB concurred with our recommendation," 

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

importance of having a sound requirements determination process for 

security clearances, Specifically, a sound requirements determination 

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

necessary. Further, the Performance Accountability Council'S reformed 

security clearance process identified determining if a position requires a 

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

clearance process begins with establishing whether a position requires a 

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

renewal clearances and the levels of such clearance requests are two 

ways to look at outcomes of requirements setting in the clearance 

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

reported that 3.9 million" federal employees (military and civilian) and 

contractors hold security clearances. Moreover, OPM reported that its 

cost to conduct background investigations for much of the executive 

branch outside the intelligence agencies increased about 79 percent from 

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

2011. 

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

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

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

number of requests to the heightened security concerns that resulted 

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

large number of investigations to an increase in the operations and 

deployments of military personnel and to the increasingly sensitive 

technology that military personnel, government employees, and 

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

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

38 These are the latest available data 

Page 21 GAO·12~815T 
50 

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

investigative and adjudicative workloads that are required to provide 

clearances and that flexibility further tax the clearance process. 

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

the investigative and adjudicative workloads. For example, top secret 

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

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

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

many investigative staff hours as the average investigative report for a 

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

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

because in our previous work, DOD officials estimated that investigative 

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

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

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

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

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

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

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

to investigate and adjudicate each top secret reinvestigation adds costs 

and workload for the government. 

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

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

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

investigation for a secret clearance. 39 As we reported in February 2012, 

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

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

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

Federal Investigative Notices are not always reflective of the amount 

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

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

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

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

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

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

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

39 These bH!ing rates are published In OPM's annual Federal Investigative Notices 

Page 22 GAO·12·81ST 
51 

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

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

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

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

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

increase investigative workload and thereby costs unnecessarily. We are 

currently reviewing the process that the executive branch uses to 

determine whether a position requires a security clearance for the 

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

expected issuance date for this report is this summer. 

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

Subcommittee. as evidenced by our removal of the DOD's security 

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

the progress that the Performance Accountability Council, and in 

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

progress by implementing recommendations, improving overall 

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

progress that has been made with respect to the overall governmentwide 

reform efforts would not be possible without committed and sustained 

leadership of Congress and by the senior leaders involved in the 

Performance Accountability Council as well as their dedicated staff. 

Continued oversight and stewardship of the reform efforts is the 

cornerstone to sustaining momentum and making future progress. As the 

executive branch continues to move forward to enhance the suitability 

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

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

Chairman Akaka, Ranking Member Johnson, and Members of the 

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

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

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

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

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

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

statement. GAO staff who made key contributions to this testimony 

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

James Krustapentus, Gregory Marchand, Jillena Roberts, and Arnie 

Steele. 

Page 23 GAO·12·815T 
52 

Related GAO Products 

Background Investigations: Office of Personnel Management Needs to 

Improve Transparency of Its Pricing and Seek Cost Savings. 

GAO-'2-197 Washington, D.C.: February 28, 2012. 

GAO's 2011 High-Risk Series: An Update. G.',O- ~ ~ -394T. Washington, 

D.C.: February 17, 2011. 

High-Risk Series: An Update. G,".o-1' -278. Washington, D.C.: February 

16,2011. 

Personnel Security Clearances: Overall Progress Has Been Made to 

Reform the Governmentwide Security Clearance Process. GAO-' 1-2321. 

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

Personnel Security Clearances: Progress Has Been Made to Improve 

Timeliness but Continued Oversight Is Needed to Sustain Momentum. 

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

DOD Personnel Clearances: Preliminary Observations on DOD's 

Progress on Addressing Timeliness and Quality Issues. GA.0-11-185T. 

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

Personnel Security Clearances: An Outcome-Focused Strategy and 

Comprehensive Reporting of Timeliness and Quality Would Provide 

Greater Visibility over the Clearance Process. G-',O-- 0- - 1 T'-. 

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

Personnel Security Clearances: Progress Has Been Made to Reduce 

Delays but Further Actions Are Needed to Enhance Quality and Sustain 

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

Personnel Security Clearances: An Outcome-Focused Strategy Is 

Needed to Guide Implementation of the Reformed Clearance Process. 

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

DOD Personnel Clearances: Comprehensive Timeliness Reporting, 

Complete Clearance Documentation, and Quality Measures Are Needed 

to Further Improve the Clearance Process. '3-'\CJ-J9-4CO. Washington, 

D.C .. May 19, 2009. 

High-Risk Series: An Update. GAO-C9-r' Washington, D.C.: January 

2009. 

Page 24 GAO~12·815T 
53 

Related GAO Products 

Personnel Security Clearances: Preliminary Observations on Joint 

Reform Efforts to I mprove the Governmentwide Clearance Eligibility 

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

Personnel Clearances: Key Factors for Reforming the Security Clearance 

Process. G."O·08·776T Washington, D.C.: May 22,2008. 

Employee Security: Implementation of Identification Cards and DOD's 

Personnel Security Clearance Program Need Improvement. 

G/\0·08·55 1 :. Washington, D.C.. April 9, 2008. 

Personnel Clearances: Key Factors to Consider in Efforts to Reform 

Security Clearance Processes. GpC"08·352T Washington, D.C.: 

February 27, 2008. 

DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts 

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

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

DOD Personnel Clearances: Improved Annual Reporting Would Enable 

More Informed CongreSSional Oversight. GI,0·08·350. Washington, D.C.: 

February 13, 2008. 

DOD Personnel Clearances: Delays and Inadequate Documentation 

Found for Industry Personnel. GAO·07·84 2T. Washington, D.C.: May 17, 

2007. 

High-Risk Series: An Update GA.O·'J7·3'c .. Washington, D.C.: January 

2007. 

DOD Personnel Clearances: Additional OMS Actions Are Needed to 

Improve the Security Clearance Process. '?AC-06- ~ 070. Washington, 

D.C .. September 28,2006. 

DOD Personnel Clearances: New Concerns Slow Processing of 

Clearances for Industry Personnel. GflO·05· 7 48:. Washington, D.C.: 

May 17, 2006. 

DOD Personnel Clearances: Funding Challenges and Other Impediments 

Slow Clearances for Industry Personnel. GAO·06· '7 47T. Washington, 

D.C.: May 17, 2006 

Page 25 GAO-12-815T 
54 

(351749) 

Related GAO Products 

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

GAC-05-233:. Washington, D.C.: November 9.2005. 

DOD Personnel Clearances: Some Progress Has Been Made but Hurdles 

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

Designation. Gp.0-05-842:. Washington, D.C.: June 28,2005. 

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

2005. 

DOD Personnel Clearances: Preliminary Observations Related to 

Backlogs and Delays in Determining Security Clearance Eligibility for 

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

Page 26 GAO-12·815T 
55 

STATEMENT OF 

DANIEL I. WERFEL 

CONTROLLER 

OFFICE OF MANAGEMENT AND BUDGET 

BEFORE THE 

COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS 

SUBCOMMITTEE ON OVERSIGHT OF GOVERNMENT MANAGEMENT, THE FEDERAL 

WORKFORCE, AND THE DISTRICT OF COLUMBIA 

UNITED STATES SENATE 

PERSONNEL SECURITY CLEARANCE REFORM: SUSTAINING PROGRESS FOR THE 

FUTURE 

JUNE 21,2012 

Chairman Akaka, Ranking Member Johnson, and Members of the Subcommittee; thank 

you for inviting me here today. It is my privilege to testify on behalf of the Office of 

Management and Budget (OMB) and to discuss the Administration's ongoing security clearance 

reform efforts, the status of implementing those reforms, and our goals for the coming year. 

This Administration has made important advances in reforming the security clearance 

process. There is still work to be done, but federal hires, military personnel, cleared contractors, 

and those personnel requiring a reinvestigation have a more effective and expedient clearance 

experience than they did just a few years ago. These reforms have saved money by reducing lost 

work days and increasing productivity as employees wait less time to perform the full spectrum 

of their jobs, ensuring that critical national security work is completed more efficiently. Today, I 

would like to share some of our accomplishments and discuss our plan to sustain this progress. 

Background and Progress 

For many years, a backlog in the government's security clearance inventory caused 

tremendous problems and significant expense. In 1994, a Department of Defense (DoD) and 
56 

Centrallntelligcnce Agency (CIA) Joint Security Commission report noted that substantial 

delays in processing clearances resulted in tremendolls unnecessary costs. primarily due to 

workers waiting to perform the jobs for which they were already hired. Over the next nine years, 

agencies made little progress addressing the longstanding coordination problems that 

compromised the timeliness and quality of the process involved in obtaining a security clearance. 

Recognizing the breadth and depth of this problem, Congress took action. In 2004, the 

Intelligence Reform and Terrorism Prevention Act (IRTPA) challenged the Federal government 

to address these issues, and in 2005, the Government Accountability Office (GAO) placed 

DoD's Personnel Security Clearance Program on its high-risk list. IRTPA required all agencies 

to complete 90 percent of their security clearances in an average of60 days by December 2009. 

As a result of actions the Executive Branch has taken to meet the objectives of IRTPA, 

the speed of the average security clearance has increased dramatically. In 2005, the governmentwide average for initial clearances was 265 days, and as recently as October 2006, the backlog of 

pending clearance investigations over 180 days old stood still at almost 100,000 cases. By 

December 2009, 90 percent of the government's initial clearances were completed within the 

IRTPA-required timeframe of 60 days. We have consistently met the IRTPA target since and the 

decades-old backlog of initial investigations is now gone. 

Importantly, Executive Branch reform efforts have also extended beyond timeliness. Tn 

order to align suitability and security policies and practices, and to establish enterprise 

information technology standards to improve efficiency and reciprocity, Executive Order 13467 

established the Suitability and Security Clearance Performance Accountability Council (PAC) in 

2008 to be accountable to the President for reform goals. The Executive Order also further 
57 

consolidated oversight by designating the Director of the Office of Personnel Management 

(OPM) and the Director of National Intelligence (DNI) as the Suitability and Security Executive 

Agents, respectively. 

The PAC has also aggressively taken on and met many reform challenges. In concert 

with the goal to increase the use of information technology in making the security and suitability 

clearance process more efficient, applicants are using an improved electronic questionnaire for 

National Security Positions, investigators have increased access to electronic record repositories, 

OPM investigations are transmitted electronically, and the PAC has completed several promising 

pilots on the effectiveness of automated record checks in support of revised federal investigative 

standards. The PAC is currently developing an implementation plan for a live-tiered 

investigative model that will streamline and facilitate greater reciprocity between suitability and 

security investigations and determinations. And perhaps most importantly, 90 percent of security 

clearance determinations last quarter were completed within 46 days, an 83 percent reduction 

from the 2005 level--exceeding the IRTPA timeliness standard. 

This significant progress, and our ongoing efforts to sustain timeliness and ensure quality, 

led GAO to remove DoD's Personnel Security Clearance Program from its high-risk list last 

year. Such impressive results are attributable to the skill and dedication of the staffat the 

Defense Department and the agencies representing the security and suitability communities, our 

partnership with GAO, effective governance, and the leadership and persistent foclls of 

Congress, and this subcommittee in particular, on these issues. 

Sustaining Progress 

3 
58 

We met IRTPA 's timeliness goals by changing long-standing practices and committing 

nccessary resources to the goals of reform. In order to sustain this progress, we are focused on 

amending the investigative and adjudicative standards to make identified efficiencies permanent 

and supporting them with further technology improvements. Today, I would like to emphasize 

our progress in several critical areas within thc larger plan: aligning suitability and security 

processes and policies; leveraging information technology solutions to improve timeliness, 

quality, and reciprocity; and providing oversight of and assistance to agencies that are lagging 

behind in security clearance reform. 

• Policy Alignment. We are aligning suitability and security policies and processes to 

limit redundancies in our investigative and adjudicative practices. To achieve this, we 

are modifying the regulatory and investigative standards, as well as the information 

collection forms, that underlie our clearance operations. For example, in August 2010, 

OrM and the Office of the Director of National Intelligence (ODNI) issued policy 

guidance to establish reciprocity between suitability determination and security clearance 

investigation levels. Furthermore, in August of20 II, ODNI issued a policy clarification 

to address discrepancies between the intelligence community and national investigation 

standards. and increase reciprocity between the two communities. In December 2011, 

OPM issued revisions to 5 eFR 731, establishing a five-year cycle of reinvestigations for 

persons occupying public trust positions, which aligned suitability and security clearance 

investigative and reinvestigation cycles. The revisions also established that separate 

investigations for the purpose of security clearance determinations or for holding 

sensitive positions arc sufficient to meet that public trust reinvestigation requirement. 

4 
59 

This alignment limited the number of investigations that individuals must undergo, but 

maintained continuous and up-to-date investigations for security and suitability. 

• Technology Solutions. We are leveraging technology to improve timeliness and quality 

by converting the paper-based application processes for National Security Positions to the 

Electronic Questionnaires for Investigations Processing (e-QIP). This has reduced both 

the number of unnecessary questions that individuals are required to answer, as well as 

mitigating the submission of incomplete forms that would cause further delays. Notably, 

over 99% of clearance application submissions to OPM are now completed 

electronically. While this process began at OPM, the PAC is now replicating the e-QIP 

technology within the intelligence community. We also continue to improve reciprocity 

between security and suitability determinations through initiatives such as enhanced 

sharing of relevant investigatory data among Federal agencies. For example, OPM's 

Central Verification System and DoD's Joint Personnel Adjudication System are 

integrated through a single interface, allowing agencies to view previous security, 

suitability, and credentialing decisions as well as investigatory information when they arc 

deciding whether to grant reciprocity for a previous clearance. 

• Oversight and Assistance. In 2009. ODNI began issuing annual letters to agencies not 

meeting IRTPA's timeliness goals. These letters require that those agencies at most risk 

establish improvement plans to address their deficiencies. In Ju Iy 20 I 0, the Security 

Executive Agent's Oversight Team began visiting individual at-risk agencies to provide 

on-site, hands-on support. As a result of this oversight and assistance, 1 am happy to 

report that 12 of the 19 agencies that initially received letters from ODNI are now fully in 

compliance with the timeliness goals established under IRTPA. In 2010, OPM began 
60 

onsite evaluations of agencies' adoption of security and suitability process reforms, 

focusing on reciprocity, investigative and adjudicative timeliness, and automation. The 

61 audits completed to date demonstrated that 23 agencies instituted appropriately 

reformed processes, and that 38 had more work to do. OPM helped those agencies 

develop corrective action plans, and is monitoring progress at six month intervals until 

full compliance is achieved. Since OPM began providing that assistance, 21 agencies 

have implemented stricter guidelines on investigation submission timeliness, 18 began 

working with OPM to update projections on a routine bases to improve compliance and 

accuracy, and 6 eliminated outdated designation processes and implemented OrM's 

automated Position Designation Tool. 

Moving Forward 

While the reform process has achieved many successes by aligning policies, leveraging 

technology, and providing appropriate oversight and assistance, work remains. Currently, we are 

finalizing revised Federal Investigative Standards. These standards will align investigations of 

individuals who require approval for obtaining logical and physical access, holding sensitive 

positions, and accessing classified information, with the separate determinations of employee 

suitability and contractor fitness. The standards will establish five tiers of successively higher 

levels of investigation and adjudications that will enable greater reciprocity of clearances among 

tiers of equal or lower risk level. OPM and ODNI expect to release these standards by the end of 

this summer. 

In order to support this tiered investigative model, we also plan to issue revisions to 

5CFR 732 in the near future, which will broaden positions that should be designated as national 

6 
61 

security sensitive and update guidance regarding proper designation of national security 

positions. We also plan to issue revised adjudicative guidelincs latcr this year. 

Finally, we are also working to support these new policy standards with continued 

technology improvements. The PAC and the Executive Agents are leading and overseeing 

interagency working groups to establish government-wide application, investigation, and 

adjudication data standards. These data standards will bring the reform effort in line with the 

November 28,2011 Presidential Memorandum on creating an efficient and cost effective 

framework for managing government records. They will enable even greater data sharing among 

suitability and security clearance reform partners, will facilitate improved case management, and 

pave the way for increased automation. Moving forward, our goals will focus on transitioning 

from increased electronic information sharing to greater automation, where appropriate. 

In all of these efforts, we will rely on the continued efforts and partnership of the PAC, 

oversight of the Security and Suitability Executive Agents, cooperative leadership of Executive 

Branch agency heads, as well as the accountability brought to bear by GAO and this 

Subcommittee, to ensure that we stay on track and do not lose momentum. 

Conclusion 

As I've outlined here today, we have made significant progress on improving the 

suitability and security clearance processes. That said, work remains to sustain the progress and 

to realize continued efficiency improvements. This reform effort remains extremely important to 

me personally, as I have been involved in these improvements since 2008. They also remain a 

high priority for this Administration. 

7 
62 

I would like to take a moment to thank you, Mr. Chairman, for your leadership. We will 

lose a key partner in your retirement, but we are proud to have accompl ished so much and to 

have established this trajectory on your watch. We look forward to our continued work with 

your colleagues on the Subcommittee. I would also like to take a moment to thank the 

extraordinary leadership of the PAC- Ms. Elizabeth McGrath, the Deputy Chief Management 

Officer from the Department of Defense (and the Vice Chair of the PAC), Mr. John Berry, the 

Director of the Office of Personnel Management, and Mr. James Clapper, the Director of 

National Intelligence. They have been instrumental in this effort. With their assistance, as well 

as the continued support of this Subcommittee, I am confident we will continue to improve the 

timeliness, reciprocity, and quality of clearance decisions. 

Once again, thank you for the opportunity to testify, and I look forward to answering 

your questions. 

8 
63 

STATEMENT BY 

THE HONORABLE ELIZABETH A. MCGRATH 

DEPUTY CHIEF MANAGEMENT OFFICER 

DEPARTMENT OF DEFENSE 

BEFORE THE 

SENATE COMMITTEE ON HOMELAND SECURITY AND 

GOVERNMENTAL AFFAIRS 

SUBCOMMITTEE ON OVERSIGHT OF GOVERNMENT MANAGEMENT, THE 

FEDERAL WORKFORCE, AND THE DISTRICT OF COLUMBIA 

OPEN HEARING ON SECURITY CLEARANCE REFORM 

JUNE 21,2012 
64 

Chairman Akaka, Senator Johnson, and Members of the Subcommittee. thank you 

for the opportunity to testify today regarding the Department of Defense's role in, and 

continued commitment to. reforming the personnel security clearance process. 

Since co-founding the Joint Reform Team five years ago. 000. working with the 

Office of Management and Budget (OM B). the Office of Personnel Management (OPM). 

and the Office of the Director of National Intelligence (DNI). has made significant 

improvements to its Department-wide personnel security clearance program. I appreciate 

the opportunity to share with you a number of important developments that have taken 

place since I last testified before this committee on this subject in November 20 I O. 

Working together. we have achieved major improvements in the timeliness of Federal 

background investigations and adjudications, and reduced duplication and waste through 

both technology enhancements and the streamlining of policy and processes. Perhaps 

most importantly, we established a key governance body - the Performance 

Accountability Council - that effectively bridges agency divides, ensures we sustain our 

progress and strives for even greater efficiencies for the future. Our efforts have resulted 

in timeliness that far exceeds goals set by Congress in the Intelligence Reform and 

Terrorism Prevention Act of2004, a superior security clearance quality program, and 

information technology systems that enhance Department-wide capabilities and are being 

studied for implementation by other government agencies. Recognizing these strides, the 

Government Accountability Office (GAO) removed the 000 Personnel Security 

Clearance Process, from its High Risk List a year ago. This marked the first time that 

GAO has removed a DoD High Risk Area since the inception of the High Risk List in 

1990. 

I applaud the significant contributions that my colleagues across the interagency 

have made to this effort and also want to sincerely thank this subcommittee for the 

leadership and encouragement that you have provided over the years. Your sustained 

attention to this matter has been invaluable in ensuring our continued improvement. 

Senator Akaka. [ especially want to thank you for your personal engagement on this issue 

and your efforts to work across the aisle to drive improvements - with Senator Yoinovieh. 

while he was here - and now with Senator Johnson. 

Importance of the Personnel Security Clearance Process 

A high quality and timely Personnel Security Clearance Process is important to 

the Department for a number of reasons. First, a high quality investigation and 

adjudication process for granting security clearances is a kcy line of defense in the 

safeguarding of classified materials. Second, a timely process is important bccause 

delays in processing security clearances can cause delays in placing qualified individuals 

2 
65 

in the cleared positions that need them to accomplish our many missions. In some cases. 

delays may result in highly qualified applicants withdrawing themselves from 

consideration for positions and the government losing out on these potential key 

contributors to our workforce. These delays are also detrimental in that they increase the 

cost of and reduce the productivity of our contracted workforce. Additionally, delays can 

be an enormous personal inconvenience for our service members and civilian employees 

as lengthy wait times degrade their personal quality of life as well as their ability to 

participate in all aspects of their professional lives. 

Role of the Performance Accountability Council 

The Suitability and Security Clearance Performance Accountability Council 

(PAC) was chartered to ensure the goals of reform are sustained across the federal 

government. Established in June 2008 as part of Executive Order 13467. "Reforming 

Processes Related to Suitability for Government Employment, Fitness for Contractor 

Employees, and Eligibility for Access to Classified National Security Information." the 

PAC is chaired by OMS's Deputy Director for Management and includes. but is not 

limited to, senior leaders of the executive branch agencies you sec seated here today. 

The advances DoD has made thus far in security clearance processing, timeliness 

and quality would not have been achieved without the dedication and top-down direction 

from the PAC. The PAC's focus on performance, quality, technological improvement. 

and standardization of key practices in investigation and adjudication has guided the 

Department's achievements I describe to you today. As the federal government's largest 

customer of investigations, we have worked vigorously with our partners OPM and 

ODNl to ensure new standards and practices in investigation and adjudication not only 

meet our needs for quality and timeliness, but also reflect the goal of modernizing longoutdated, cold war era formulas and provide data relevant to the norms and behaviors of a 

21 51 century workforce. Not content to he a demanding customer. we have scoured our 

internal processes and standards for conducting adjudications and raised our game. vying 

for best-in-government timelincs. while fortifying underlying quality assurance programs 

with improved guidance and cnterprise wide technological tools. These results represent 

the progress possible when an agency commits to goals informed by interagency 

priorities and collaboration. It has been an honor to serve as the vice-chair of the PJ\C, 

and to playa role in helping to reform not only the Department's performance. but 

government wide clearance processes. This subcommittee. in particular. has been a 

champion of the PAC's work, and I am grateful for your continued emphasis on its 

effectiveness in realizing the benefits of reform. 

3 
66 

Next, I'd like to discuss some specific initiatives the Department has executed in 

response to the priorities for clearance reform. 

Timeliness Improvements 

The Intelligence Reform and Terrorism Prevention Act 01'2004 directs agencies 

to conduct adjudicative determininations in no more than 20 days. At the end of the 

second quarter of FY12, the average timeliness for the fastest 90% of DoD's adjudication 

of initial confidential, Secret, and Top Secret investigations was down to a fleet 7 days. 

DoD's success in improving adjudication timeliness is due in large part to the 

development and deployment of an electronic adjudication (e-Adjudication) capability 

through the DoD's Case Adjudication Tracking System (CATS). CATS was developed 

initially by the Army and has since been deployed across all DoD components. 

As part of our interagency reform efforts, the DN! issued eAdjudication business 

rules for adjudicating non-issue National Agency Checks with Local Agency Chccks and 

Crcdit Checks (NACLC). The NACLC is the investigation conducted on all military 

accessions personnel who do not require access to Top Secret classified information and 

all contractor personnel requiring access to Secret classified information. Between April 

20 II and March 2012, 228,285 NACLC investigations were processed through eAdjudication. Of these, 98,655 or 24% were able to be completed with no manual 

processing required in the course of adjudication, allowing our adjudicators to spend their 

time more effectivcly and efficiently on cases of greater complexity and potential risk. 

CA TS is gaining users in other federal agencies. The Department of Energy has 

adopted CATS for e-Adjudication of its clearance cases and the Social Security 

administration is scheduled to deploy CATS e-adjudication capability in FYI 3. Business 

rules have been approved and are being piloted within the Department for application of 

e-Adjudication to additional investigation types. 

DoD Investigative and Adjudicative Quality Improvements 

In November 2009, the Office of the Under Secretary of Defense (Intelligence) 

established a program called the Review of Adjudicative Documentation Accuracy and 

Rationales (RADAR). RADAR is DoD's assessment tool for measuring the quality of 

adjudicative documentation within DoD's non-Intelligence Community Central 

Adjudication Facilities (CAFs). In our most recent assessment, DoD excceded its 90% 

compliance benchmark with 92% of adjudications evaluated meeting documentation 

standards. 

4 
67 

In March 20 I O. Senators Akaka and Voinovich. the Chairman and then-ranking 

member of this subcommittee, directed GAO to develop quality measures for clearance 

investigations and adjudications and suggested that OMB, OPM. 000, and DNI do the 

same. The subcommittee was rightly concerned that our gains in timeliness of security 

clearances should not be at the expense of investigative and adjudieative quality. In 

response to the Committee's suggestion, the 000 committed to three adjudication quality 

benchmarks: (l) quality of adjudicative determinations: (2) percent of adjudications 

reviewed and approved by certified adjudicators; and (3) percent of certified adjudicators. 

GAO recommended that 000 issue guidance clarifying when adjudicators may 

use incomplete investigative reports as a basis for granting clearances. [n March 20 I O. 

000 established guidance for adjudicating investigations with missing or incomplete 

information. Later that year, 000 deployed the Rapid Assessment oflneomplete 

Security Evaluations (RAISE) electronic tool to assess personnel security investigation 

quality. RAISE is administered through CATS and, using a random sample method. 

flags eases to be rated and identifies investigations with missing or incomplete 

information. RAISE has been deployed at each of the 000 non-Intelligence Community 

(IC) CAFs and is being considered as a basis for standardizing investigative quality 

across the federal government. 

To promote quality through eomprehensive and standardized training of 

adjudicators, the 000 initiated an Adjudieator Certification Program (ACP) in July of 

20 I O. This program became fully operational in September 20 I 0, and 000 adjudication 

facilities were given two years to implement and comply with certification requirements 

for all personnel. As of this month, 81 % of adjudicators are certified and the 000 is on 

target to achieve 90% certification by September 15,2012. 

Challenges for the Future 

Opportunities within the reform program are many, none more compelling than 

the need to ensure the Executive Branch is continuing to align processes and reduce 

duplicativc technology and invcstments where possible. Under Secretary Panetta's 

leadership, 000 continues to emphasize reducing duplication, overhead, and excess 

spending. Personnel across the Department are tasked with streamlining activities, 

instilling a culture of savings and accountability, and identifying and executing savings. 

These values are shared across the Federal Government. 

Continuing our efforts to utilize technology also deserves our sustained support. 

As [ have detailed, the Department has leveraged enterprise tools (eAdjudication, CATS 

and RAISE) to improve its internal operations, and regularly seeks to partner externally 

5 
68 

to move closer to the vision of end-to-end automation. The PAC recognizes this as an 

area of future promise and is committed to identifying the next, best steps to advance our 

technological capabilities. 

Conclusion 

While much has been achieved. it remains critically important that Members of 

this Committee, 000, DNI, OPM, OMB and GAO continue to collaborate on ways to 

deliver greater efficiencies and cost-effectiveness in background investigations and 

adjudications. Our sustained commitment to working together leaves me confident that 

we will be able to take on the challenges that lie ahead. 

1 want to close by again thanking you, Chairman Akaka, and this subcommittee 

for your attention to, and oversight of. security clearance reform over the years. Your 

commitment to the highest values of interagency cooperation and utmost consideration 

for our taxpayers, war fighters. industry partners. and civil servants has resulted in 

dramatic progress in our government's ability to better deliver security clearances to the 

people who need them without compromising national security. It is upon this 

foundation of success that we will strive for even greater gains in the future. 

6 
69 

UNITED STATES OFFICE OF PERSONNEL MANAGEMENT 

STATEMENT OF 

MERTON W. MILLER 

ASSOCIATE DIRECTOR 

U.S. OFFICE OF PERSONNEL MANAGEMENT, FEDERAL INVESTIGATIVE 

SERVICES 

before the 

SUBCOMMITTEE ON OVERSIGHT OF GOVERNMENT MANAGEMENT, THE 

FEDERAL WORKFORCE, AND THE DISTRICT OF COLUMBIA, COMMITTEE ON 

HOMELAND SECRUITY AND GOVERNMENT AFFAIRS, UNITED STATES SENATE 

on 

SECURITY CLEARANCE REFORM: SUSTAINING PROGRESS FOR THE FUTURE 

June 21, 2012 

Chairman Akaka, Ranking Member Johnson, and Members of the Subcommittee: 

On behalf of Director Berry, I want to thank you for the opportunity to testify today regarding 

the U.S. Office of Personnel Management's (OPM) role in security clearance reform and our 

efforts in achieving and sustaining the tremendous progress made in the security clearance and 

investigation process. I am also pleased to have the opportunity to thank Chairman Akaka and 

this Subcommittee for their leadership in correcting a decades old problem through investigative 

consolidation, legislative performance goals, and supporting security clearance reform efforts. I 

am also pleased to have the opportunity to extend OPM's gratitude and best wishes to Chairman 

Akaka and thank him for his many years of service to our country. 

From the beginning, OPM has been deeply committed to overhauling the security clearance 

'process, and working closely with our partners - the Office of Management and Budget (OMB), 

Congressional and Legislative AITa;rs • 1900 E Street. N. W • Room SIBO • Washington. DC 20-1 I 5 • 202-606-1300 
70 

Statement of Merton W. Miller 

Associate Director 

U.S. Office of Personnel Management, Federal Investigative Services 

June 21, 2012 

the Office of the Director of National Intelligence (ODNI), and the Department of Defense 

(DOD) - to implement reforms that improved timeliness, efficiency, and quality of the security 

clearance and investigation process. Today, OPM's background investigation program's 

performance is strong, as demonstrated by years of providing timely and quality products to our 

customer agencies. We have no backlogs, are meeting timeliness mandates, and have increased 

automation. OPM looks forward to continuing our partnerships and improving on our successes 

as we shift towards executing our executive agent responsibilities. 

OPM's Efforts and Accomplishments to Provide Timely, High-Quality Investigations 

and Implementing Security Clearance Reform as a Member of the Suitability and 

Security Clearance Performance Accountability Council (PAC): 

Investigation Timeliness: OPM's background investigation program has unfailingly met 

timeliness and quality expectations for our customers - while consistently meeting the challenges 

of an ever-growing investigative workload (since FY 2005, our workloads have increased 

significantly - 26 percent increase in top secret investigations, 21 percent for secret/confidential 

investigations, and 144 percent in top secret reinvestigations). During this same period, we also 

eliminated an inherited backlog. Yet, we met and exceeded the government-wide timeliness 

goals mandated in the Intelligence Reform and Terrorism Prevention Act of 2004, and have 

sustained this level of performance to date. 

FY 2012 to date Percent Improved 

Type ofInvestigation FY 2005 

(June 1, 2012) since 2005 

All Initial Security Investigations 145 days 36 days 75% 

Top Secret I Q 308 days 72 days 77% 
71 

Statement of Merton W. Miller 

Associate Director 

U.S. Office of Personnel Management, Federal Investigative Services 

June 21, 2012 

Secret/Confidential / L 115 days 31 days 73% 

Reinvestigations for Top Secret / Q 419 days 93 days 78% 

By improving investigation timeliness and eliminating backlogs, OPM has enabled agencies to 

put people to work more quickly, thereby saving the Federal government billions of dollars. 

Investigation Quality: The quality of our investigation program remains a top priority - as 

demonstrated by years of meeting PAC quality metrics and supported by continued reform 

enhancements. We ensure the quality of our investigation products by actively pursuing 

feedback from our customer agencies and maintaining a robust internal quality control process. 

In addition, we have incorporated reform initiatives into our process, such as aligning our 

existing investigative products with the proposed tiered investigation model. This simplified 

approach has streamlined processes and promotes reciprocity throughout the Federal 

government. We enhanced the quality of our investigative products by implementing an updated 

electronic Standard Form 86, which collects more information up front from the applicant and 

targets issue information for expansion, and implemented enhanced subject interview techniques. 

Additionally, we have partnered with ODNI to create an inter-agency Quality Assessment 

Working Group to establish Federal quality measures and standards for evaluating investigative 

products. These key reform enhancements promote quality by using investigative resources 

more effectively and efficiently and providing agencies with relevant adjudicative information to 

make critical security clearance decisions. 
72 

Statement of Merton W. Miller 

Associate Director 

U.S. Office of Personnel Management, Federal Investigative Services 

June 21, 2012 

RefOrm Initiatives: OPM continues to work closely with members of the PAC to reform the 

security clearance and investigation process. The following highlights some of the initiatives 

that have been successfully implemented over the past couple years and the areas benefited from 

these initiatives. 

I) Reciprocity. Today, reciprocity is fully enabled with relevant security clearance, 

suitability, and identity data shared across the Federal government. By implementing an 

automated position designation tool and expanding the data stored in the Central 

Verification System (CVS), agencies can more accurately determine the proper level of 

investigation to be conducted. By building a pass through to DOD's Joint Personnel 

Adjudication System, CVS is the standard for clearance validation for most of the Federal 

government. 

2) Electronic Application. OPM's Electronic Questionnaires for Investigations Processing 

(e-QIP) is the gold standard for electronic application throughout the Federal 

government. Statistics show the system improves the quality of agency submissions and 

speeds the initiation of the investigation process. Currently, OPM receives over 99 

percent of all security investigation requests through e-QIP, with many agencies, such as 

DOD and OPM, at 100 percent. In addition, we continue to work with other investigation 

service providers to implement e-QIP in their organizations. Specifically, we enabled eQIP pass-through use for other agencies with delegated investigative authorities and 

provided the source code to allow the intelligence community to replicate e-QIP on their 

classified systems. 
73 

Statement of Merton W. Miller 

Associate Director 

U.S. Office of Personnel Management, Federal Investigative Services 

June 21, 2012 

3) Investigation Process. OPM has fully aligned our current investigative products with all 

aspects of the reformed investigative model supported by current policies, and following 

a detailed cost assessment, are poised to implement the new Federal investigative 

standards. In addition to aligning our existing investigation products with the tiered 

model and enhanced investigation techniques, we have taken additional steps to 

streamline and improve the investigation process. For example, we have added 

additional agency checks, such as Social Security number and CVS records, and have 

migrated previously manual record checks for criminal history and birth verification to 

automated checks. 

4) Agency Ad;udications. OPM enhanced investigative delivery processes that have 

supported electronic adjudication methods and reduced agency adjudication 

timeliness. OPM revised our case seriousness coding and incorporated the use of 

machine-readable coding, known as XML tagging, into portions of the investigation 

product to aid the electronic adjudication process. OPM expanded the use of electronic 

delivery of completed investigations to our customer agencies, delivering over 3.2 

million investigations to 53 participating agencies. OPM also developed and 

implemented PAC-approved standardized suitability adjudicator training, thereby 

promoting the consistent application of adjudication standards across government and 

reciprocal acceptance of agency suitability decisions. 

OPM's Workforce Planning and Other Strategies to Ensure an Effective Investigative 

Staff 

OPM currently manages a balanced nation-wide Federal and contract workforce to provide a 

flexible, responsive, and cost-effective investigative program. Our core Federal investigator 
74 

Statement of Merton W. Miller 

Associate Director 

U.S. Office of Personnel Management, Federal Investigative Services 

Jnne 21, 2012 

presence permits us to appropriately manage highly sensitive and inherently governmental 

investigative requirements while our contractor presence permits us to expand and contract 

operations as the workload numbers and locations dictate. OPM has expanded the pool of 

contractors who have the capability to conduct background investigations which has driven 

meaningful competition providing us the best possible price. 

Our strategies to ensure an effective investigative staff includes targeted training enhancements, 

realigned quality structured organization, and automated tools and system support. OPM cochaired the PAC Training Subcommittee to develop core competencies, skill standards, and 

training objectives for background investigators and security/suitability adjudicators that were 

approved by the PAC as the national training standards. The Suitability and Security Executive 

Agents will inform the Executive Branch agencies of the national standards. 

At OPM, we transformed our National Training Center into a professional cadre of certified 

instructors and instructional system specialists who develop and provide core training and 

professional development to our investigative staff, contractors, and other agencies. OPM 

implemented an automated Learning Management System that provides online training 

capabilities. Finally, we are in the process of obtaining accreditation for our basic Background 

Investigator and Suitability Adjudicator training programs through the Federal Law Enforcement 

Training Accreditation. Upon accreditation, we will have the first and only Federally accredited 

personnel security investigation training program in the country. 
75 

Statement of Merton W. Miller 

Associate Director 

U.S. Office of Personnel Management, Federal Investigative Services 

June 21, 2012 

Enhanced Investigatory Capabilities and Improvements to Information Technology 

In addition to our certified training program, OPM is working on other initiatives that will 

enhance the content of our investigations. OPM is co-chairing a number of Executive Branch 

working groups aimed at implementing the new Federal investigative standards. This includes 

developing data standards for consistent formatting of investigative results and data sharing; 

developing quality expectations and measures for the revised standards; and identifYing bestpractices for enhanced investigative capabilities across the investigations enterprise. We are also 

exploring social media information for investigative leads and data mining benefits and 

standardizing investigative policy across the Executive Branch. 

In addition, OPM will continue to work with Federal, State, and local record providers to 

streamline collection methods and identifY information that will enhance the content of the 

investigation. We are also developing automated solutions that will aid our investigators in 

preparing for interviews and reporting the results. OPM will also continue our efforts to 

streamline processes through our Business Process Reengineering Effort where we will map 

future "to-be" processes to take full advantage offuture information technology capabilities. 

OPM is also engaged in the transformation of our EPIC 1 suite of automated tools. The goals of 

the EPIC transformation are to improve the timeliness and quality of the investigation process, 

enable standardization, support reform, and protect and secure investigation information. 

The EPIC acronym is derived from the names of four critical systems: E - "e-QIP"; P - "Personnel 

Investigations Processing System";, I - "Imaging"; and C - "CVS". 
76 

Statement of Merfon W. Miller 

Associate Director 

U.S. Office of Personnel Management, Federal Investigative Services 

June 21, 2012 

The EPIC transfonnation includes platfonn enhancements to update hardware and software, 

implement an event driven architecture, and use relational database functionality to increase 

system flexibility. As we progress through the modernization project, with the completion of 

each release, our capabilities arid efficiencies are enhanced, contributing directly to improved 

investigative timeliness and cost savings. OPM is on track to complete the EPIC transfonnation 

by 2014, giving us the technical agility and flexibility needed to sustain timeliness and quality 

and to keep pace with changing investigative program demands. 

The Way Forward 

I am extremely proud of the progress OPM has made in refonning the investigations program. 

Through our joint partnership with OMB, ODNI, and DOD, we have successfully worked 

through and overcome many challenges, including: consolidating and aligning the background 

investigations program; balancing workforce requirements; eliminating significant workload 

backlogs; satisfying aggressive timeliness requirements; professionalizing training; monitoring 

perfonnance; developing advanced automation; and refonning processes to enhance quality. 

Across the Executive Branch, refonn has enjoyed the leadership of the PAC, with specific 

support of the PAC subcommittees, the Joint Refonn Team, and the Executive Branch working 

groups that have worked to establish and operationalize the Joint Security and Suitability Refonn 

process. It is because of these important partnerships that I can speak with full confidence about 

the future of the investigations program and the security and suitability process. 

Thank you for the opportunity to testify today, and I look forward to answering your questions. 
77 

UNCLASSIFIED STATEMENT FOR THE RECORD 

ON SECURITY CLEARANCE REFORM 

FOR THE 

SUBCOMMITTEE ON OVERSIGHT OF GOVERNMENT MANAGEMENT. THE 

FEDERAL WORKFORCE, AND THE DISTRICT OF COLUMBIA, 

SENATE COMMITTEE ON HOMELAND SECURITY AND 

GOVERNMENTAL AFFAIRS 

MR. CHARLES B. SOWELL 

DEPUTY ASSISTANT DIRECTOR fOR SPECIAL SECURITY. OFFICE OF THE 

DIRECTOR OF NATIONAL INTELLlGENCE 

JUNE 21,2012 
78 

Introduction 

Chairman Akaka. Ranking Member Johnson. distinguished Members of the 

Subcommittee: Thank you for this opportunity to discuss the progress we have made on 

security clearance reform. I am pleased to appear beside the principal partners of reform 

- the Department of Defense (000). the Office of Personnel Management (OPM) and the 

Office of Management and Budget (OMB) - who together work to ensure that 

improvements to timeliness. quality. and reciprocity are institutionalized and sustained. 

Director Clapper continues to give extensive time and attention to this effort, and 

he recognizes that his role as Security Executive Agent (SecEA) is key to continuing the 

significant progress we have made in transforming the end-to-end security clearance 

process across the Federal Government. Clearance reform truly remains one of his top 

priorities. 

We greatly appreciate the strong bipartisan support this initiative has received 

from this subcommittee, particularly Senator Akaka during your tenure as Chairman. and 

look forward to continuing our partnership with this committee and our fellow agencies 

across the Government to ensure further success. 

Today I would like to focus my remarks on the Office of the Director of National 

Intelligence's (ODN!) efforts and accomplishments as the SccEA to implement 

comprehensive security clearance reform. highlight best practices in the Intelligence 

Community's (lC) clearance process that can be applied government-wide. and discuss 

some remaining challenges in standardizing policies and practiccs. 

2 
79 

Accomplishments as the Security Executive Agent 

Over the past two years, we have focused our efforts on institutionalizing the 

DNl's responsibilities as Security Executive Agent for the Government. In August 20 II, 

we issued a policy clarification to eliminate discrepancies between intelligence 

community and national investigative standards, which immediately eliminated 

redundancy and improved government-wide reciprocity. In March 2012, the DNI issued 

Security Executive Agent Directive 1 (SEAD 1), a landmark publication, applicable US 

Government-wide, which provides a clear andcomprehensive description of the SecEA's 

authorities and responsibilities. SEAD 1 applies to all departments and agencies 

performing investigations or adjudications of persons proposed for eligibility to hold a 

sensitive position whether or not requiring access to classified information. The ODNI 

also led the inter-agency efforts to revise the National Security Adjudicative Guidelines 

which we expect to issue later this year. 

Through his Security Executive Agent responsibilities, the DNI continues to 

support the Suitability and Security Clearance Performance Accountability Council's 

(PAC) goals of aligning security and suitability, and improving quality, timeliness and 

reciprocity. Our most mature oversight function is tracking and reporting security 

clearance timeliness data from agencies across the Government. Based on this data, the 

DNI began issuing annual letters in 2009 to departments and agencies not meeting the 

timeliness goals required by IRTPA for initial clearances. Over the past year we have 

refined our annual letters and added periodic reinvestigation timeliness and backlog 

numbers to assist agencies to focusing on those critical areas. 

3 
80 

In January 2012, the DNI sent letters to 46 departments and agencies addressing 

their 2011 performance. Twenty-two agencies met the timeliness goals for all of201 I, 

nineteen agencies met the goals for some of the year, and only five agencies did not meet 

the goals and were directed to provide improvement plans. Of particular note. four of thc 

five agencies which did not meet the goals in 2011 actually improved their performance 

throughout the year which dcmonstrated their commitment and progress. The military 

services, the Departments of Commerce, Energy, State, Transportation, Treasury and 

Veterans Affairs, OPM, Federal Bureau of Investigation, and National Security Agency 

are among the organizations that met the goals for all of 20 Ii. I also want to highlight 

the Defense Security Service's Defense Industrial Security Clearance Office (DISCO). 

which met its timeliness goals for industry for the first time ever in 2011 and has 

continued to meet the goals for the past year. 

DISCO's improved performance is tied to DoD's automated Case Adjudication 

Tracking System (CATS) which electronically adjudicates clean cases at the Secret level. 

This award-winning tool is a great example of DoD's powerful innovative capabilities to 

use automation for a more efficient allocation of adjudicative resources. DoD's efforts to 

share its automated adjudicative capability with other governmcnt agencies demonstrates 

government partnering at its best. 

The dedicated oversight and assessment from this committee, the Government 

Accountability Office, the Security and Suitability Executive Agents, the PAC and the 

individual agencies and departments have combined to dramatically improve the 

government-wide avcrage for initial clearances from 265 days in 2005 to 46 days in the 

4 
81 

second quarter of FY 2012. We believe this is a clear demonstration of the power of 

partnership. 

Tn addition to his oversight role, the DN! believes we must be responsive to 

department and agency emerging requirements and constrained resources. We hold 

quarterly Security Executive Agent Advisory Committee meetings with representatives 

from across the Government where we share ideas. best practices. and update each other 

on key policy. technology and training initiatives. We rotate these meetings throughout 

the Washington area with individual agencies hosting them. Past hosts include the State 

Department and Defense Security Service. and the Central Intelligence Agency is hosting 

our next meeting later this month. 

Several agencies have approached the SecEA for guidance on using publicly 

available social media in the background investigation process. We have formed a 

working group to explore this issue and provide recommendations that will protect 

privacy and civil liberties while allowing the use of this emerging source of data; a 

SecEA Directive has also been drafted for coordination throughout the community. We 

have formed a working group to establish national level reporting requirements for 

individuals who are eligible or granted access to classified information. Working with 

our partners throughout both the IC and all of Government. we will standardize the way 

people report issues like foreign travel. 

OPM is a critical partner, as the Suitability Executive Agent and largest 

investigative services provider for the Government. In August 2010, the ODNI and OPM 

join!!y issued policy guidance which aligned suitability determination and security 

clearance investigation levels. essentially establishing reciprocity among them. The 

5 
82 

OD;-.JI and OPM have co-chaired the inter-agency Federal Investigative Standards (FIS) 

Working Group, tasked with revision of the FIS to align security and suitability 

investigations. Last month OPM and OONI partnered to establish the PIS Implementation 

Working Group (FISIWG) that includes participation by all federal agencies with 

investigative authority. The FISIWG will collaboratively develop a high-level project 

plan, implementation strategy and time lines, deliverables and follow-on activities 

required for phased implementation of the revised Standards across the Federal 

Government. We are working with OPM to rcvisc Background Investigator Training 

Standards to standardize training for background investigations. as well as Security and 

Suitability Adjudicator Training Standards. These training programs have been endorsed 

by the Performance Accountability Council. In the future, OPM and the OONI will 

conduct joint assessments of agencies with suitability and security clearance investigation 

and adjudication authority. Our strong partnership will help us implement the reformed 

security clearance process and continue to make further improvements. 

There is still work to do. We continue to focus on ensuring reciprocal acceptance 

of existing security clcaranccs bctween agencies. To that end. we have put in place a 

rcciprocity web page hosted on the SecEA Website that provides education and 

awareness, a checklist of exceptions, policy references, and examples of non-reciprocity 

issues. Another reciprocity initiative is the effort to document all 000 collateral 

clearances in Scattered Castles (SC); further, SC now includes fields that better support 

reciprocity. Measuring reciprocity is difficult. and despite an abundance of anecdotes. 

real data is hard to come by. To address this problem, we are developing a web-based 

form for individuals to submit their experience with reciprocity issues to the OON!. This 

6 
83 

will allow us, for the first time to collect empirical data, perform systemic trend analysis, 

and assist agencies with achieving workable solutions. 

We have partnered with numerous industry associations to identify and address 

long-standing reciprocity issues. Industry is uniquely affected by reciprocity problems, 

and they have provided key insight to understanding the potential impact of a variety of 

SecEA efforts to make improvements. The ODN[ is also a member of the National 

Industry Security Program Policy Advisory Committee (NISPPAC) and we have recently 

briefed our fellow members on the reciprocity website and web-based form initiative. 

Best Practices in the IC Applicable Government-wide 

One of the best practices in the IC security clearance process that can be applied 

government-wide is the continuous monitoring of cleared personnel, such as the program 

that NSA has implemented. Personnel security and CI professionals from NSA 

collaborate on initiatives to improve the timely detection of potential insider threats. 

Automated record checks are used to makc re-evaluations more cost-effective. reduce 

adverse impact on agency resources and facilitate agency monitoring of employee 

conduct between standard reinvestigation cycles. Potential CI threats or associations are 

identified for further investigation. 

As previously mentioned, the IC is exploring the use of social media in thc 

clearance vetting process. An inter-agency working group is developing a 

recommendation to the SecEA for a government-wide social media policy and 

implementation strategy to use open source publically available electronic information to 

enhance security vetting, while respecting individual privacy and civil liberties. We are 

also reviewing data from government agencies and industry vendors suggesting potential 

7 
84 

value in publically available electronic information on the internet. Several IC agencies 

are considering initiatives to conduct pilots involving checks of social media sites to 

determine cost-benefit. We expect to have a final recommendation to SecEA on 

government-wide applicability by December 2012. 

Challenges in Developing Standardized Polieies and Procedures Relating to the 

Security Clearance Process 

Different formats of electronic and paper-based record systems at the federal. 

state and local levels, individual agency information protection policies and technology 

limitations pose some of the biggest challenges to improving further the security 

clearanee process. To address these ehallenges, the PAC is re-establishing the Reeords 

Repository Working Group (RR WG) which will foeus on improving information sharing 

and records exehange. [n addition, the ODNI has formed a Data Standards Working 

Group (OSWG) with membership including all investigative service providers and 

agencies that conduct or adjudicate background investigations. The group is creating a 

standard by which all investigative data can be exchanged between organizations 

electronically. This achieves a number of purposes, including: 

• Standardization of electronic data format and XML tagging of security 

background information 

• Easy electronic transfer of data for reciprocity, reinvestigation, and adjudication 

• Increased capability to use electronic adjudication 

• Electronic (versus paper) storage of security "jackets" 

• Reduction in the labor. time, and cost associated with rekeying and transporting 

physical fi les 

8 
85 

Æ 

In addition to benefiting the broader Government as the IC moves ahead with its 

Information Technology Enterprise initiative. opportunities to leverage the work of the 

DSWG will abound. 

Conclusion 

Director Clapper is intent on creating a strong, effective Security Executive Agent 

capability for improvement of Government operations and efficiency. We hope the 

initiatives we have outlined demonstrate that. 

Mr. Chairman, on behalf of Director Clapper. we appreciate your exceptional 

leadership on, and dedication to, security clearance reform. I hope our collective efforts 

and successes give you reassurance that time and energy you have devoted to this 

important national security capability has been very well spent. We look forward to 

continuing the partnership with our fellow agencies and this Subcommittee as we 

continue to strengthen our clearance processes in defense of the nation. 

9