PERSONNEL SECURITY 

CLEARANCES

Full Development and 

Implementation of Metrics 

Needed to Measure Quality 

of Process

Statement of Brenda S. Farrell, Director

Defense Capabilities and Management

Testimony 

Before the Committee on Homeland 

Security and Governmental Affairs, 

U.S. Senate

For Release on Delivery 

Expected at 10:00 a.m. EDT

Thursday, October 31, 2013

GAO-14-157T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-157T, a testimony 

before the Committee on Homeland Security 

and Governmental Affairs, U.S. Senate

October 31, 2013

PERSONNEL SECURITY CLEARANCES

Full Development and Implementation of Metrics 

Needed to Measure Quality of Process

Why GAO Did This Study

A high-quality personnel security 

clearance process is necessary to 

minimize the associated risks of 

unauthorized disclosures of classified 

information and to help ensure that 

information about individuals with 

criminal activity or other questionable 

behavior is identified and assessed as 

part of the process for granting or 

retaining clearances. Personnel 

security clearances allow individuals 

access to classified information that, 

through unauthorized disclosure, can 

in some cases cause exceptionally 

grave damage to U.S. national 

security. In 2012, the DNI reported that 

more than 4.9 million federal 

government and contractor employees 

held or were eligible to hold a security 

clearance. GAO has reported that the 

federal government spent over $1 

billion to conduct background 

investigations (in support of security 

clearances and suitability 

determinations—the consideration of 

character and conduct for federal 

employment) in fiscal year 2011.

This testimony addresses the (1) 

overall security clearance process, 

including roles and responsibilities; and 

(2) extent that executive branch 

agencies have metrics to help 

determine the quality of the security 

clearance process. This testimony is 

based on GAO work issued between 

2008 and 2013 on DOD’s personnel 

security clearance program and 

governmentwide suitability and security 

clearance reform efforts. As part of that 

work, GAO (1) reviewed statutes, 

federal guidance, and processes, (2) 

examined agency data on the 

timeliness and quality of investigations 

and adjudications, (3) assessed reform 

efforts, and (4) reviewed samples of 

case files for DOD personnel.

What GAO Found

Multiple executive branch agencies are responsible for different steps of the 

multi-phased personnel security clearance process that includes: determination 

of whether a position requires a clearance, application submission, investigation, 

and adjudication. Agency officials must first determine whether a federal civilian 

position requires access to classified information. The Director of National 

Intelligence (DNI) and the Office of Personnel Management (OPM) are in the 

process of issuing a joint revision to the regulations guiding this step in response 

to GAO’s 2012 recommendation that the DNI issue policy and guidance for the 

determination, review, and validation of requirements. After an individual has 

been selected for a federal civilian position that requires a personnel security 

clearance and the individual submits an application for a clearance, 

investigators—often contractors—from OPM conduct background investigations 

for most executive branch agencies. Adjudicators from requesting agencies use 

the information from these investigations and consider federal adjudicative 

guidelines to determine whether an applicant is eligible for a clearance. Further, 

individuals are subject to reinvestigations at intervals that are dependent on the 

level of security clearance. For example, top secret and secret clearance holders 

are to be reinvestigated every 5 years and 10 years, respectively. 

Executive branch agencies have not fully developed and implemented metrics to 

measure quality throughout the personnel security clearance process. For more 

than a decade, GAO has emphasized the need to build and monitor quality 

throughout the personnel security clearance process to promote oversight and 

positive outcomes such as maximizing the likelihood that individuals who are 

security risks will be scrutinized more closely. For example, GAO reported in May 

2009 that, with respect to initial top secret clearances adjudicated in July 2008 for 

the Department of Defense (DOD), documentation was incomplete for most of 

OPM’s investigative reports. GAO independently estimated that 87 percent of 

about 3,500 investigative reports that DOD adjudicators used to make clearance 

eligibility decisions were missing some required documentation, such as the 

verification of all of the applicant’s employment. GAO also estimated that 12 

percent of the 3,500 reports did not contain the required personal subject 

interview. In 2009, GAO recommended that OPM measure the frequency with 

which its investigative reports met federal investigative standards in order to 

improve the quality of investigation documentation. As of August 2013, however, 

OPM had not implemented this recommendation. GAO’s 2009 report also 

identified issues with the quality of DOD adjudications. Specifically, GAO

estimated that 22 percent of about 3,500 initial top secret clearances that were 

adjudicated favorably did not contain all the required documentation. As a result, 

in 2009 GAO recommended that DOD measure the frequency with which 

adjudicative files meet requirements. In November 2009, DOD issued a 

memorandum that established a tool called the Review of Adjudication 

Documentation Accuracy and Rationales (RADAR) to measure the frequency 

with which adjudicative files meet the requirements of DOD regulation. According 

to a DOD official, RADAR had been used in fiscal year 2010 to evaluate some 

adjudications, but was not used in fiscal year 2011 due to funding shortfalls. DOD 

restarted the use of RADAR in fiscal year 2012. 

View GAO-14-157T. For more information, 

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

FarrellB@gao.gov.
Page 1 GAO-14-157T 

Chairman Carper, Ranking Member Coburn, and Members of the 

Committee:

Thank you for the opportunity to be here to participate in this discussion 

of the federal government’s process for personnel security clearances. A 

high-quality personnel security clearance process is necessary to 

minimize the associated risks of unauthorized disclosures of classified 

information and to help ensure that information about individuals with 

criminal activity or other questionable behavior is identified and assessed 

as part of the process for granting or retaining clearances. However, 

recent events, such as unauthorized disclosures of classified information, 

have shown that there is more work to be done by federal agencies to 

help ensure the process functions effectively and efficiently, so that only 

trustworthy individuals obtain and keep security clearances and the 

resulting access to classified information that clearances make possible.

As you know, we have an extensive body of work on issues related to the 

personnel security clearance process going back over a decade. Since 

2008, we have focused on the government-wide effort to reform the 

security clearance process. Personnel security clearances allow 

government and industry personnel (contractors) to gain access to 

classified information that, through unauthorized disclosure, can in some 

cases cause exceptionally grave damage to U.S. national security. It is 

important to keep in mind that security clearances allow for access to 

classified information on a need to know basis. Federal agencies also use 

other processes and procedures to determine if an individual should be 

granted access to certain government buildings or facilities or be 

employed as either a military, federal civilian employee, or contractor for 

the federal government. Separate from, but related to, personnel security 

clearances are determinations of suitability that the executive branch 

uses to ensure individuals are suitable, based on character and conduct, 

for federal employment in their agency or position.

The federal government processes a high volume of personnel security 

clearances at significant costs. In 2012, the Director of National 

Intelligence (DNI) reported that more than 4.9 million federal government 

and contractor employees held or were eligible to hold a security 

clearance, which poses a formidable challenge to those responsible for 

deciding who should be granted a clearance. Furthermore, the federal 

government spent over $1 billion to conduct more than 2 million 

background investigations (in support of both personnel security 

clearances and suitability determinations for government employment 

outside of the intelligence community) in fiscal year 2011. The 
Page 2 GAO-14-157T 

Department of Defense (DOD) accounts for the majority of all personnel 

security clearances—which includes 788,000 background investigations 

that cost over $787 million in fiscal year 2011.1

My testimony today will focus on two topics related to personnel security 

clearances. First, I will discuss the overall personnel security clearance 

process, including roles and responsibilities for investigations and 

adjudications. Second, I will discuss the extent that executive branch 

agencies have developed and implemented metrics to help determine the 

quality of the security clearance process.

My testimony is based on our reports and testimonies issued from 2008 

through 2013 on DOD’s personnel security clearance program and 

government-wide suitability and security clearance reform efforts. A list of 

these related products appears at the end of my statement. As part of the 

work for these products, we reviewed statutes, federal guidance and 

processes, examined agency data on the timeliness and quality of 

investigations and adjudications, assessed reform efforts, and reviewed a 

sample of investigative and adjudication files for DOD personnel. The 

work upon which this testimony is based was conducted in accordance 

with generally accepted government auditing standards. Those standards 

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

evidence to provide a reasonable basis for our findings and conclusions 

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

provides a reasonable basis for our findings and conclusions based on 

our audit objectives. Further details about the scope and methodology 

can be found in each of these related products.

Multiple executive-branch agencies have key roles and responsibilities for 

different steps of the federal government’s personnel security clearance 

process. For example, in 2008, Executive Order 134672 designated the 

DNI as the Security Executive Agent. As such, the DNI is responsible for 

developing policies and procedures to help ensure the effective, efficient, 

 1

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

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

28, 2012). 

2

Executive Order No. 13467, Reforming Processes Related to Suitability for Government 

Employment, Fitness for Contractor Employees, and Eligibility for Access to Classified 

National Security Information (June 30, 2008). 

The Overall Personnel 

Security Clearance 

Process
Page 3 GAO-14-157T 

and timely completion of background investigations and adjudications 

relating to determinations of eligibility for access to classified information 

and eligibility to hold a sensitive position. In turn, executive branch 

agencies determine which of their positions—military, civilian, or privateindustry contractors—require access to classified information and, 

therefore, which people must apply for and undergo a personnel security 

clearance investigation. Investigators—often contractors—from Federal 

Investigative Services within the Office of Personnel Management (OPM)3

conduct these investigations for most of the federal government using 

federal investigative standards and OPM internal guidance as criteria for 

collecting background information on applicants.4 OPM provides the 

resulting investigative reports to the requesting agencies for their internal 

adjudicators, who use the information along with the federal adjudicative 

guidelines to determine whether an applicant is eligible for a personnel 

security clearance. DOD is OPM’s largest customer, and its Under 

Secretary of Defense for Intelligence (USD(I)) is responsible for 

developing, coordinating, and overseeing the implementation of DOD 

policy, programs, and guidance for personnel, physical, industrial, 

information, operations, chemical/biological, and DOD Special Access 

Program security. Additionally, the Defense Security Service, under the 

authority, direction, and control of USD(I), manages and administers the 

 3

OPM’s Federal Investigative Services employs both federal and contract investigators to 

conduct work required to complete background investigations. The federal staff constitutes 

about 25 percent of that workforce, while OPM currently also has contracts for 

investigative fieldwork with several investigation firms, constituting the remaining 75 

percent of its investigative workforce.

4

In 2005, the Office of Management and Budget designated OPM as the agency 

responsible for, among other things, the day-to-day supervision and monitoring of security 

clearance investigations, and for tracking the results of individual agency-performed 

adjudications, subject to certain exceptions. However, the Office of the Director of National 

Intelligence can designate other agencies as an "authorized investigative agency” 

pursuant to 50 U.S.C. § 3341(b)(3), as implemented through Executive Order 13467. 

Alternatively, under 5 U.S.C. § 1104(a)(2), OPM can redelegate any of its investigative 

functions subject to performance standards and a system of oversight prescribed by OPM 

under 5 U.S.C. § 1104(b). Agencies without delegated authority rely on OPM to conduct 

their background investigations while agencies with delegated authority—including the 

Defense Intelligence Agency, National Security Agency, National Geospatial-Intelligence 

Agency, Central Intelligence Agency, Federal Bureau of Investigation, National 

Reconnaissance Office, and Department of State—have been authorized to conduct their 

own background investigations. 
Page 4 GAO-14-157T 

DOD portion of the National Industrial Security Program5 for the DOD 

components and other federal agencies by agreement, as well as 

providing security education and training, among other things.

Section 3001 of the Intelligence Reform and Terrorism Prevention Act of 

20046 prompted government-wide suitability and security clearance 

reform. The act required, among other matters, an annual report to 

Congress—in February of each year from 2006 through 2011—about 

progress and key measurements on the timeliness of granting security 

clearances. It specifically required those reports to include the periods of 

time required for conducting investigations and adjudicating or granting 

clearances. However, the Intelligence Reform and Terrorism Prevention 

Act requirement for the executive branch to annually report on its 

timeliness expired in 2011. More recently the Intelligence Authorization 

Act of 20107 established a new requirement that the President annually 

report to Congress the total amount of time required to process certain 

security clearance determinations for the previous fiscal year for each 

element of the Intelligence Community.8 The Intelligence Authorization 

Act of 2010 additionally requires that those annual reports include the 

total number of active security clearances throughout the United States 

government, to include both government employees and contractors. 

Unlike the Intelligence Reform and Terrorism Prevention Act of 2004 

reporting requirement, the requirement to submit these annual reports 

does not expire.

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

(ODNI) formed the Joint Security Clearance Process Reform Team, 

known as the Joint Reform Team, to improve the security clearance 

process government-wide. In a 2008 memorandum, the President called 

for a reform of the security clearance and suitability determination 

 5

The National Industrial Security Program was established by Executive Order 12829 to 

safeguard Federal Government classified information that is released to contractors, 

licensees, and grantees of the United States Government. Executive Order 12829,

National Industrial Security Program (Jan. 6, 1993, as amended).

6

Pub. L. No. 108-458 (2004) (relevant sections codified at 50 U.S.C. § 3341). 

7

Pub. L. No. 111-259, § 367 (2010) (codified at 50 U.S.C. § 3104). 

8

This timeliness reporting requirement applies only to the elements of the Intelligence 

Community; it does not cover non-intelligence agencies that were covered by the reporting 

requirements in the Intelligence Reform and Terrorism Prevention Act of 2004.
Page 5 GAO-14-157T 

processes and subsequently issued Executive Order 13467,9 which in 

addition to designating the DNI as the Security Executive Agent, also 

designated the Director of OPM as the Suitability Executive Agent. 

Specifically, the Director of OPM, as Suitability Executive Agent, is 

responsible for developing policies and procedures to help ensure the 

effective, efficient, and timely completion of investigations and 

adjudications relating to determinations of suitability, to include 

consideration of an individual’s character or conduct. Further, the 

executive order established a Suitability and Security Clearance 

Performance Accountability Council to oversee agency progress in 

implementing the reform vision. Under the executive order, this council is 

accountable to the President for driving implementation of the reform 

effort, including ensuring the alignment of security and suitability 

processes, holding agencies accountable for implementation, and 

establishing goals and metrics for progress. The order also appointed the 

Deputy Director for Management at the Office of Management and 

Budget as the chair of the council.10

In the first step of the personnel security clearance process, executive 

branch officials determine the requirements of a federal civilian position, 

including assessing the risk and sensitivity level associated with that 

position, to determine whether it requires access to classified information 

and, if required, the level of access. Security clearances are generally 

categorized into three levels: top secret, secret, and confidential.11 The 

level of classification denotes the degree of protection required for 

information and the amount of damage that unauthorized disclosure could 

 9

Executive Order No. 13467, Reforming Processes Related to Suitability for Government 

Employment, Fitness for Contractor Employees, and Eligibility for Access to Classified 

National Security Information (June 30, 2008). 

10The Performance Accountability Council is comprised of the Director of National 

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

Executive Agent, and the Deputy Director for Management, Office of Management and 

Budget, as the chair with the authority to designate officials from additional agencies to 

serve as members. As of June 2012, the council included representatives from the 

Departments of Defense, Energy, Health and Human Services, Homeland Security, State, 

Treasury, and Veterans Affairs, and the Federal Bureau of Investigation.

11A top secret clearance is generally also required for access to Sensitive Compartmented 

Information—classified intelligence information concerning or derived from intelligence 

sources, methods, or analytical processes that is required to be protected within formal 

access control systems established and overseen by the Director of National Intelligence. 

Steps in the Personnel 

Security Clearance 

Process
Page 6 GAO-14-157T 

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

A sound requirements process is important because requests for 

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

level of clearance increase investigative workloads and costs. In 2012, we 

reported that the DNI, as the Security Executive Agent, had not provided 

agencies clearly defined policy and procedures to consistently determine 

if a position requires a security clearance, or established guidance to 

require agencies to review and revise or validate existing federal civilian 

position designations.12 We recommended that the DNI issue policy and 

guidance for the determination, review, and validation of requirements, 

and ODNI concurred with those recommendations, stating that it 

recognized the need to issue or clarify policy. Currently, OPM and ODNI 

are in the process of issuing a joint revision to the regulations guiding 

requirements determination. Specifically, according to officials from the 

ODNI, these offices had obtained permission from the President to reissue the federal regulation jointly, drafted the proposed rule, and 

obtained public input on the regulation by publishing it in the Federal 

Register. According to ODNI and OPM officials, they will jointly review 

and address comments and prepare the final rule for approval from the 

Office of Management and Budget.

Once an applicant is selected for a position that requires a personnel 

security clearance, the applicant must obtain a security clearance in order 

to gain access to classified information. While different departments and 

agencies may have slightly different personnel security clearance 

processes, the phases that follow—application submission, investigation, 

and adjudication—are illustrative of a typical process.13 Since 1997, 

federal agencies have followed a common set of personnel security 

investigative standards and adjudicative guidelines for determining 

whether federal civilian workers, military personnel, and others, such as 

private industry personnel contracted by the government, are eligible to 

hold a security clearance. Figure 1 illustrates the steps in the personnel 

security clearance process, which is representative of the general 

 12GAO, Security Clearances: Agencies Need Clearly Defined Policy for Determining 

Civilian Position Requirements, GAO-12-800 (Washington, D.C.: July 12, 2012). 

13The general process for performing a background investigation for either a secret or top 

secret clearance is the same; however, the level of detail and types of information 

gathered for a top secret clearance is more substantial than a secret clearance. 
Page 7 GAO-14-157T 

process followed by most executive branch agencies and includes 

procedures for appeals and renewals.
Page 8 GAO-14-157T 

Figure 1: Steps in the Personnel Security Clearance Process

a

OPM provides background investigation services to over 100 executive branch agencies; however, 

others, including some agencies in the Intelligence Community, have been delegated authority from 

the Office of the Director of National Intelligence, OPM, or both, to conduct their own background 

investigations.
Page 9 GAO-14-157T 

During the application submission phase, a security officer from an 

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

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

(Standard Form 86) using OPM’s electronic Questionnaires for 

Investigations Processing (e-QIP) system or a paper copy of the Standard 

Form 86 to the individual to complete; (3) reviews the completed 

questionnaire; and (4) sends the questionnaire and supporting

documentation, such as fingerprints and signed waivers, to OPM or its 

investigation service provider.

During the investigation phase, investigators—often contractors—from 

OPM’s Federal Investigative Services use federal investigative standards 

and OPM’s internal guidance to conduct and document the investigation 

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

depends on the needs of the client agency and the personnel security 

clearance requirements of an applicant’s position, as well as whether the 

investigation is for an initial clearance or a reinvestigation to renew a 

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

investigators gather additional information through more time-consuming 

efforts, such as traveling to conduct in-person interviews to corroborate 

information about an applicant’s employment and education. However, 

many background investigation types have similar components. For 

instance, for all investigations, information that applicants provide on 

electronic applications are checked against numerous databases. Both 

secret and top secret investigations contain credit and criminal history 

checks, while top secret investigations also contain citizenship, public 

record, and spouse checks as well as reference interviews and an 

Enhanced Subject Interview to gain insight into an applicant’s character. 

Table 1 highlights the investigative components generally associated with 

the secret and top secret clearance levels. After OPM, or the designated 

provider, completes the background investigation, the resulting 

investigative report is provided to the adjudicating agency.
Page 10 GAO-14-157T 

Table 1: Information Gathered in Conducting a Typical Investigation to Determine Suitability and Eligibility for a Personnel 

Security Clearance

Type of information gathered by component

Type of background 

investigation

Secret Top Secret

1. Personnel security questionnaire: The reported answers on an electronic SF-85P or SF-86 

form

X X

2. Fingerprints: Fingerprints submitted electronically or manually X X

3. National agency check: Data from Federal Bureau of Investigation, military records, and 

other agencies as required (with fingerprint) 

X X

4. Credit check: Data from credit bureaus where the subject lived/worked/attended school for 

at least 6 months 

X X

5. Local agency checks: Data from law enforcement agencies where the subject 

lived/worked/attended school during the past 10 years or—in the case of reinvestigations—

since the last security clearance investigation 

X X

6. Date and place of birth: Corroboration of information supplied on the personnel security 

questionnaire 

X

7. Citizenship: For individuals born outside of the United States, verification of U.S. citizenship 

directly from the appropriate registration authority 

X

8. Education: Verification of most recent or significant claimed attendance, degree, or diploma V X

9. Employment: Review of employment records and interviews with workplace references, 

such as supervisors and coworkers

V X

10. References: Data from interviews with subject-identified and investigator-developed leads V X

11. National agency check for spouse or cohabitant: Data from Federal Bureau of Investigation, 

military records, and other agencies as required (without fingerprint)

X

12. Former spouse: Data from interview(s) conducted with spouse(s) divorced within the last 10 

years or since the last investigation or reinvestigation

X

13. Neighborhoods: Interviews with neighbors and verification of residence through records 

check 

V X

14. Public records: Verification of issues, such as bankruptcy, divorce, and criminal and civil 

court cases 

X

15. Enhanced Subject Interview: Collection of relevant data, resolution of significant issues or 

inconsistencies 

a X

Source: DOD and OPM

Note: The content and amount of information collected as part of a personnel security clearance 

investigation is dependent on a variety of case-specific factors, including the history of the applicant 

and the nature of the position; however, items 1-15 are typically collected for the types of 

investigations indicated.

V = Components with this notation are checked through a mail voucher sent by OPM’s Federal 

Investigative Services.

a

The Enhanced Subject Interview was developed by the Joint Reform Team and implemented by 

OPM in 2011 and serves as an in-depth discussion between the interviewer and the subject to ensure 

a full understanding of the applicant’s information, potential issues, and mitigating factors. It is 

included in a Minimum Background Investigation, one type of suitability investigation, and can be 

triggered by the presence of issues in a secret level investigation.
Page 11 GAO-14-157T 

During the adjudication phase, adjudicators from the hiring agency14 use 

the information from the investigative report to determine whether an 

applicant is eligible for a security clearance. To make clearance eligibility 

decisions, the adjudication guidelines specify that adjudicators consider 

13 specific areas that elicit information about (1) conduct that could raise 

security concerns and (2) factors that could allay those security concerns 

and permit granting a clearance.15 If a clearance is denied or revoked, 

appeals of the adjudication decision are possible. We have work 

underway to review the process for security revocations. We expect to 

issue a report on this process by spring of 2014.

Once an individual has obtained a personnel security clearance and as 

long as they remain in a position that requires access to classified 

national security information, that individual is reinvestigated periodically 

at intervals that are dependent on the level of security clearance. For 

example, top secret clearance holders are reinvestigated every 5 years, 

and secret clearance holders are reinvestigated every 10 years. Some of 

the information gathered during a reinvestigation would focus specifically 

 14For industry personnel, the Defense Security Service (DSS) adjudicated clearance 

eligibility for DOD and 24 other federal agencies, by agreement, using OPM-provided 

investigative reports. However, DOD is in the process of consolidating its adjudication 

facilities, including those for industry personnel. Per DOD 5220.22-M, National Industrial 

Security Program: Operating Manual (Feb. 28, 2006 incorporating changes Mar. 28, 

2013), those agencies are: (1) National Aeronautics and Space Administration; (2) 

Department of Commerce; (3) General Services Administration; (4) Department of State; 

(5) Small Business Administration; (6) National Science Foundation; (7) Department of the 

Treasury; (8) Department of Transportation; (9) Department of the Interior; (10) 

Department of Agriculture; (11) Department of Labor; (12) Environmental Protection 

Agency; (13) Department of Justice; (14) Federal Reserve System; (15) Government 

Accountability Office; (16) U.S. Trade Representative; (17) U.S. International Trade 

Commission; (18) U.S. Agency for International Development; (19) Nuclear Regulatory 

Commission; (20) Department of Education; (21) Department of Health and Human 

Services; (22) Department of Homeland Security; (23) Federal Communications 

Commission; and (24) Office of Personnel Management.

15Federal guidelines state that clearance decisions require a common sense 

determination of eligibility for access to classified information based upon careful 

consideration of the following 13 areas: allegiance to the United States; foreign influence; 

foreign preference; sexual behavior; personal conduct; financial considerations; alcohol 

consumption; drug involvement; emotional, mental, and personality disorders; criminal 

conduct; security violations; outside activities; and misuse of information technology 

systems. Further, the guidelines require adjudicators to evaluate the relevance of an 

individual’s overall conduct by considering factors such as the nature, extent, and 

seriousness of the conduct; the circumstances surrounding the conduct, to include 

knowledgeable participation; the frequency and recency of the conduct; and the 

individual’s age and maturity at the time of the conduct, among others.
Page 12 GAO-14-157T 

on the period of time since the last approved clearance, such as a check 

of local law enforcement agencies where an individual lived and worked 

since the last investigation. Further, the Joint Reform Team began an 

effort to review the possibility of continuous evaluations, which would 

ascertain on a more frequent basis whether an eligible employee with 

access to classified information continues to meet the requirements for 

access. Specifically, the team proposed to move from periodic review to 

that of continuous evaluation, meaning annually for top secret and similar 

positions and at least once every five years for secret or similar positions, 

as a means to reveal security-relevant information earlier than the 

previous method, and provide increased scrutiny on populations that 

could potentially represent risk to the government because they already 

have access to classified information. The current federal investigative 

standards state that the top secret level of security clearances may be 

subject to continuous evaluation.

The executive branch has developed some metrics to assess quality at 

different phases of the personnel security clearance process; however, 

those metrics have not been fully developed and implemented. To 

promote oversight and positive outcomes, such as maximizing the 

likelihood that individuals who are security risks will be scrutinized more 

closely, we have emphasized, since the late 1990s,16 the need to build 

and monitor quality throughout the personnel security 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. 

However, we have previously reported that executive branch agencies 

have not fully developed and implemented metrics to measure quality in 

key aspects of the personnel security clearance process, including: (1) 

investigative reports; (2) adjudicative files; and (3) the reciprocity of 

personnel security clearances, which is an agency’s acceptance of a 

background investigation or clearance determination completed by any 

authorized investigative or adjudicative executive branch agency.

 16GAO, DOD Personnel: Inadequate Personnel Security Investigations Pose National 

Security Risks, GAO/NSIAD-00-12 (Washington, D.C.: Oct. 27, 1999).

Full Development and 

Implementation of 

Metrics Needed to 

Determine Quality of 

Personnel Security 

Clearance Process
Page 13 GAO-14-157T 

We have previously identified deficiencies in OPM’s investigative 

reports—results from background investigations—but as of August 2013 

OPM had not yet implemented metrics to measure the completeness of 

these reports. OPM supplies about 90 percent of all federal clearance 

investigations, including those for DOD. For example, in May 2009 we 

reported that, with respect to DOD initial top secret clearances 

adjudicated in July 2008, documentation was incomplete for most OPM 

investigative reports. We independently estimated that 87 percent of 

about 3,500 investigative reports that DOD adjudicators used to make 

clearance decisions were missing at least one type of documentation 

required by federal investigative standards. The type of documentation 

most often missing from investigative reports was verification of all of the 

applicant’s employment, followed by information from the required 

number of social references for the applicant and complete security 

forms. We also estimated that 12 percent of the 3,500 investigative 

reports did not contain a required personal subject interview.

At the time of our 2009 review, OPM did not measure the completeness 

of its investigative reports, which limited the agency’s ability to explain the 

extent or the reasons why some reports were incomplete. As a result of 

the incompleteness of OPM’s investigative reports on DOD personnel, we 

recommended in May 2009 that OPM measure the frequency with which 

its investigative reports meet federal investigative standards, so that the 

executive branch can identify the factors leading to incomplete reports 

and take corrective actions.17

In a subsequent February 2011 report, we noted that OMB, ODNI, DOD, 

and OPM leaders had provided congressional members with metrics to 

assess the quality of the security clearance process, including 

investigative reports and other aspects of the process.18 For example, the 

Rapid Assessment of Incomplete Security Evaluations was one tool the 

executive branch agencies planned to use for measuring quality, or 

 17GAO, DOD Personnel Clearances: Comprehensive Timeliness Reporting, Complete 

Clearance Documentation, and Quality Measures Are Needed to Further Improve the 

Clearance Process, GAO-09-400 (Washington, D.C.: May 19, 2009). 

18GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011).

Metrics Not Yet 

Implemented to Measure 

Completeness of OPM 

Investigative Reports
Page 14 GAO-14-157T 

completeness, of OPM’s background investigations.19 However, 

according to an OPM official in June 2012, OPM chose not to use this 

tool. Instead, OPM opted to develop another tool. In following up on our 

2009 recommendations, as of August 2013, OPM had not provided 

enough details on its tool for us to determine if the tool had met the intent 

of our 2009 recommendation, and included the attributes of successful 

performance measures identified in best practices, nor could we 

determine the extent to which the tool was being used.

OPM also assesses the quality of investigations based on voluntary 

reporting from customer agencies. Specifically, OPM tracks investigations 

that are (1) returned for rework from the requesting agency, (2) identified 

as deficient using a web-based customer satisfaction survey, or (3) 

identified as deficient through adjudicator calls to OPM’s quality hotline. 

However, in our past work, we have noted that the number of 

investigations returned for rework is not by itself a valid indicator of the 

quality of investigative work because DOD adjudication officials told us 

that they have been reluctant to return incomplete investigations in 

anticipation of delays that would impact timeliness. Further, relying on 

agencies to voluntarily provide information on investigation quality may 

not reflect the quality of OPM’s total investigation workload. We are 

beginning work to further review OPM’s actions to improve the quality of 

investigations.

We have also reported that deficiencies in investigative reports affect the 

quality of the adjudicative process. Specifically, in November 2010, we 

reported that agency officials who utilize OPM as their investigative 

service provider cited challenges related to deficient investigative reports 

as a factor that slows agencies’ abilities to make adjudicative decisions. 

The quality and completeness of investigative reports directly affects 

adjudicator workloads, including whether additional steps are required 

before adjudications can be made, as well as agency costs. For example, 

some agency officials noted that OPM investigative reports do not include 

complete copies of associated police reports and criminal record checks. 

Several agency officials stated that in order to avoid further costs or 

delays that would result from working with OPM, they often choose to 

 19The Rapid Assessment of Incomplete Security Evaluations tool was developed by DOD 

to track the quality of investigations conducted by OPM for DOD personnel security 

clearance investigations, measured as a percent of investigations completed that 

contained deficiencies. 
Page 15 GAO-14-157T 

perform additional steps internally to obtain missing information. 

According to ODNI and OPM officials, OPM investigators provide a 

summary of police and criminal reports and assert that there is no policy 

requiring inclusion of copies of the original records. However, ODNI 

officials also stated that adjudicators may want or need entire records as 

critical elements may be left out. For example, according to Defense 

Office of Hearings and Appeals officials, in one case, an investigator’s 

summary of a police report incorrectly identified the subject as a thief 

when the subject was actually the victim.

DOD has taken some intermittent steps to implement measures to 

determine the completeness of adjudicative files to address issues 

identified in our 2009 report regarding the quality of DOD adjudications. In 

2009, we found that some clearances were granted by DOD adjudicators 

even though some required data were missing from the OPM 

investigative reports used to make such determinations. For example, we 

estimated in our 2009 review that 22 percent of the adjudicative files for 

about 3,500 initial top secret clearances that were adjudicated favorably 

did not contain all the required documentation, even though DOD 

regulations require that adjudicators maintain a record of each favorable 

and unfavorable adjudication decision and document the rationale for 

granting clearance eligibility to applicants with security concerns revealed 

during the investigation.20 Documentation most frequently missing from 

adjudicative files was the rationale for granting security clearances to 

applicants with security concerns related to foreign influence, financial 

considerations, and criminal conduct. At the time of our 2009 review, 

DOD did not measure the completeness of its adjudicative files, which 

limited the agency’s ability to explain the extent or the reasons why some 

files are incomplete.

In 2009, we made two recommendations to improve the quality of 

adjudicative files. First, we recommended that DOD measure the 

frequency with which adjudicative files meet requirements, so that the 

executive branch can identify the factors leading to incomplete files and 

include the results of such measurement in annual reports to Congress 

 20DOD Regulation 5200.2-R, DOD Personnel Security Program (Jan. 1987, incorporating 

changes Feb. 23, 1996).

DOD Has Taken Steps to 

Implement Measures to 

Determine Completeness 

of Adjudicative Files
Page 16 GAO-14-157T 

on clearances.21 In November 2009, DOD subsequently issued a 

memorandum that established a tool to measure the frequency with which 

adjudicative files meet the requirements of DOD regulation. Specifically, 

the DOD memorandum stated that it would use a tool called the Review 

of Adjudication Documentation Accuracy and Rationales, or RADAR, to 

gather specific information about adjudication processes at the 

adjudication facilities and assess the quality of adjudicative 

documentation. In following up on our 2009 recommendations, as of 

2012, a DOD official stated that RADAR had been used in fiscal year 

2010 to evaluate some adjudications, but was not used in fiscal year 2011 

due to funding shortfalls. DOD restarted the use of RADAR in fiscal year 

2012.

Second, we recommended that DOD issue guidance to clarify when 

adjudicators may use incomplete investigative reports as the basis for 

granting clearances. In response to our recommendation, DOD’s 

November 2009 guidance that established RADAR also outlines the 

minimum documentation requirements adjudicators must adhere to when 

documenting personnel security clearance determinations for cases with 

potentially damaging information. In addition, DOD issued guidance in 

March 2010 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.

While some efforts have been made to develop quality metrics, agencies 

have not yet implemented metrics for tracking the reciprocity of personnel 

security clearances, which is an agency’s acceptance of a background 

investigation or clearance determination completed by any authorized 

investigative or adjudicative executive branch agency. Although executive 

branch agency officials have stated that reciprocity is regularly granted, 

as it is an opportunity to save time as well as reduce costs and 

investigative workloads, we reported in 2010 that agencies do not 

consistently and comprehensively track the extent to which reciprocity is 

 21GAO, DOD Personnel Clearances: Comprehensive Timeliness Reporting, Complete 

Clearance Documentation, and Quality Measures Are Needed to Further Improve the 

Clearance Process, GAO-09-400 (Washington, D.C.: May 19, 2009). 

Metrics Not Yet 

Implemented to Measure 

Clearance Reciprocity
Page 17 GAO-14-157T 

granted government-wide.22 ODNI guidance requires, except in limited 

circumstances, that all Intelligence Community elements “accept all inscope23 security clearance or access determinations.” Additionally, Office 

of Management and Budget guidance24 requires agencies to honor a 

clearance when (1) the prior clearance was not granted on an interim or 

temporary basis; (2) the prior clearance investigation is current and inscope; (3) there is no new adverse information already in the possession 

of the gaining agency; and (4) there are no conditions, deviations, 

waivers, or unsatisfied additional requirements (such as polygraphs) if the 

individual is being considered for access to highly sensitive programs.

While the Performance Accountability Council has identified reciprocity as 

a government-wide strategic goal, we have found that agencies do not 

consistently and comprehensively track when reciprocity is granted, and 

lack a standard metric for tracking reciprocity.25 Further, while OPM and 

the Performance Accountability Council have developed quality metrics 

for reciprocity, the metrics do not measure the extent to which reciprocity 

is being granted. For example, OPM created a metric in early 2009 to 

track reciprocity, but this metric only measures the number of 

investigations requested from OPM that are rejected based on the 

existence of a previous investigation and does not track the number of 

cases in which an existing security clearance was or was not successfully 

honored by the agency. Without comprehensive, standardized metrics to 

 22In addition to establishing objectives for timeliness, the Intelligence Reform and 

Terrorism Prevention Act of 2004 established requirements for reciprocity, which is an 

agency’s acceptance of a background investigation or clearance determination completed 

by any authorized investigative or adjudicative executive branch agency, subject to certain 

exceptions such as completing additional requirements like polygraph testing. Further, in 

October 2008, ODNI issued guidance on the reciprocity of personnel security clearances. 

ODNI, Intelligence Community Policy Guidance 704.4, Reciprocity of Personnel Security 

Clearance and Access Determinations (Oct. 2, 2008). 

23Although there are broad federal investigative guidelines, the details and depth of an 

investigation varies by agency depending upon its mission. 

24Office of Management and Budget, Memorandum for Deputies of Executive 

Departments and Agencies: Reciprocal Recognition of Existing Personnel Security 

Clearances (Dec. 12, 2005); Office of Management and Budget, Memorandum for 

Deputies of Executive Departments and Agencies: Reciprocal Recognition of Existing 

Personnel Security Clearances (July 17, 2006). 

25GAO, Personnel Security Clearances: Progress Has Been Made to Improve Timeliness 

but Continued Oversight Is Needed to Sustain Momentum, GAO-11-65 (Washington, 

D.C.: Nov. 19, 2010).
Page 18 GAO-14-157T 

track reciprocity and consistent documentation of the findings, decision 

makers will not have a complete picture of the extent to which reciprocity 

is granted or the challenges that agencies face when attempting to honor 

previously granted security clearances.

In 2010, we reported that executive branch officials routinely honor other 

agencies’ security clearances, and personnel security clearance 

information is shared between OPM, DOD, and, to some extent, 

Intelligence Community databases.26 However, we found that some 

agencies find it necessary to take additional steps to address limitations 

with available information on prior investigations, such as insufficient 

information in the databases or variances in the scope of investigations, 

before granting reciprocity. For instance, OPM has taken steps to ensure 

certain clearance data necessary for reciprocity are available to 

adjudicators, such as holding interagency meetings to determine new 

data fields to include in shared data. However, we also found that the 

shared information available to adjudicators contains summary-level 

detail that may not be complete. As a result, agencies may take steps to 

obtain additional information, which creates challenges to immediately 

granting reciprocity.

Further, in 2010 we reported that because there is no government-wide 

standardized training and certification process for investigators and 

adjudicators, according to agency officials, a subject’s prior clearance 

investigation and adjudication may not meet the standards of the inquiring 

agency. Although OPM has developed some training, security clearance 

investigators and adjudicators are not required to complete a certain type 

or number of classes. As a result, the extent to which investigators and 

adjudicators receive training varies by agency. Consequently, as we have 

previously reported, agencies are reluctant to be accountable for 

investigations and/or adjudications conducted by other agencies or 

organizations.27 To achieve fuller reciprocity, clearance-granting agencies 

seek to have confidence in the quality of prior investigations and 

adjudications.

 26GAO-11-65.

27GAO, Personnel Clearances: Key Factors to Consider in Efforts to Reform Security 

Clearance Processes, GAO-08-352T (Washington, D.C.: Feb. 27, 2008).
Page 19 GAO-14-157T 

Consequently, we recommended in 2010 that the Deputy Director of 

Management, Office of Management and Budget, in the capacity as Chair 

of the Performance Accountability Council, should develop 

comprehensive metrics to track reciprocity and then report the findings 

from the expanded tracking to Congress. Although OMB agreed with our 

recommendation, a 2011 ODNI report found that Intelligence Community 

agencies experienced difficulty reporting on reciprocity. The agencies are 

required to report on a quarterly basis the number of security clearance 

determinations granted based on a prior existing clearance as well as the 

number not granted when a clearance existed. The numbers of reciprocal 

determinations made and denied are categorized by the individual’s 

originating and receiving organizational type: (1) government to 

government, (2) government to contractor, (3) contractor to government, 

and (4) contractor to contractor. The report stated that data fields 

necessary to collect the information described above do not currently 

reside in any of the datasets available and the process was completed in 

an agency specific, semi-manual method. Further, the Deputy Assistant 

Director for Special Security of the Office of the Director of National 

Intelligence noted in testimony in June 2012 that measuring reciprocity is 

difficult, and despite an abundance of anecdotes, real data is hard to 

come by. To address this problem, ODNI is developing a web-based form 

for individuals to submit their experience with reciprocity issues to the 

ODNI. According to ODNI, this will allow them to collect empirical data, 

perform systemic trend analysis, and assist agencies with achieving 

workable solutions.

As previously discussed, DOD accounts for the majority of security 

clearances within the federal government. We initially placed DOD’s 

personnel security clearance program on our high-risk list28 in 2005 

because of delays in completing clearances.29 It remained on our list until 

2011 because of ongoing concerns about delays in processing 

clearances and problems with the quality of investigations and 

adjudications. In February 2011, we removed DOD’s personnel security 

 28Every two years at the start of a new Congress, GAO issues a report that identifies 

government operations that are high risk due to their vulnerabilities to fraud, waste, abuse, 

and mismanagement, or are most in need of transformation to address economy, 

efficiency, or effectiveness. 

29GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.: Jan. 1, 2005).

Sustained Leadership 

Needed to Fully Develop 

and Implement Metrics to 

Monitor and Track Quality
Page 20 GAO-14-157T 

clearance program from our high-risk list largely because of the 

department’s demonstrated progress in expediting the amount of time 

processing clearances.30 We also noted DOD’s efforts to develop and 

implement tools to evaluate the quality of investigations and 

adjudications.

Even with the significant progress leading to removal of DOD’s program 

from our high-risk list, we noted in June 2012 that sustained leadership 

would be necessary to continue to implement, monitor, and update 

outcome-focused performance measures. The initial development of 

some tools and metrics to monitor and track quality not only for DOD but 

government-wide were positive steps; however, full implementation of 

these tools and measures government-wide have not yet been realized. 

While progress in DOD’s personnel security clearance program resulted 

in the removal of this area from our high-risk list, significant governmentwide challenges remain in ensuring that personnel security clearance 

investigations and adjudications are high-quality.

In conclusion, oversight of the reform efforts to measure and improve the 

quality of the security clearance process—including background 

investigations—are imperative next steps. Failing to do so increases the 

risk of damaging, unauthorized disclosures of classified information. The 

progress that was made with respect to expediting the amount of time 

processing clearances would not have been possible without committed 

and sustained congressional oversight and the leadership of the 

Performance Accountability Council. Further actions are needed now to 

fully develop and implement metrics to oversee quality at every step in 

the process. Chairman Carper, Ranking Member Coburn, this concludes 

my prepared statement. I would be pleased to answer any questions that 

you or other Members of the Committee may have at this time.

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

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

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

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this statement. GAO staff who made key contributions to 

 30GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011).

GAO Contacts and 

Acknowledgment
Page 21 GAO-14-157T 

this testimony include Lori Atkinson (Assistant Director), Darreisha Bates, 

Renee Brown, John Van Schaik, and Michael Willems.
Related GAO Products

Page 22 GAO-14-157T 

Personnel Security Clearances: Further Actions Needed to Improve the 

Process and Realize Efficiencies. GAO-13-728T. Washington, D.C.: June 

20, 2013.

Managing for Results: Agencies Should More Fully Develop Priority Goals 

under the GPRA Modernization Act. GAO-13-174. Washington, D.C.: 

April 19, 2013.

Security Clearances: Agencies Need Clearly Defined Policy for 

Determining Civilian Position Requirements. GAO-12-800. Washington, 

D.C.: July 12, 2012.

Personnel Security Clearances: Continuing Leadership and Attention Can 

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

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

2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue. 

GAO-12-342SP. Washington, D.C.: February 28, 2012.

Background Investigations: Office of Personnel Management Needs to 

Improve Transparency of Its Pricing and Seek Cost Savings. 

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

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

D.C.: February 17, 2011.

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

16, 2011.

Personnel Security Clearances: Overall Progress Has Been Made to 

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

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

Personnel Security Clearances: Progress Has Been Made to Improve 

Timeliness but Continued Oversight Is Needed to Sustain Momentum. 

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

DOD Personnel Clearances: Preliminary Observations on DOD’s 

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

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

Related GAO Products
Related GAO Products

Page 23 GAO-14-157T 

Personnel Security Clearances: An Outcome-Focused Strategy and 

Comprehensive Reporting of Timeliness and Quality Would Provide 

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

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

Personnel Security Clearances: Progress Has Been Made to Reduce 

Delays but Further Actions Are Needed to Enhance Quality and Sustain 

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

Personnel Security Clearances: An Outcome-Focused Strategy Is 

Needed to Guide Implementation of the Reformed Clearance Process. 

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

DOD Personnel Clearances: Comprehensive Timeliness Reporting, 

Complete Clearance Documentation, and Quality Measures Are Needed 

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

D.C.: May 19, 2009.

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

2009.

Personnel Security Clearances: Preliminary Observations on Joint 

Reform Efforts to Improve the Governmentwide Clearance Eligibility 

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

Personnel Clearances: Key Factors for Reforming the Security Clearance 

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

Employee Security: Implementation of Identification Cards and DOD’s 

Personnel Security Clearance Program Need Improvement. 

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

Personnel Clearances: Key Factors to Consider in Efforts to Reform 

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

February 27, 2008.

DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts 

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

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

DOD Personnel Clearances: Improved Annual Reporting Would Enable 

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

February 13, 2008.
Related GAO Products

Page 24 GAO-14-157T 

DOD Personnel Clearances: Delays and Inadequate Documentation 

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

2007.

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

2007.

DOD Personnel Clearances: Additional OMB Actions Are Needed to 

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

D.C.: September 28, 2006.

DOD Personnel Clearances: New Concerns Slow Processing of 

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

May 17, 2006.

DOD Personnel Clearances: Funding Challenges and Other Impediments 

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

D.C.: May 17, 2006.

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

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

DOD Personnel Clearances: Some Progress Has Been Made but Hurdles 

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

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

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

2005.

DOD Personnel Clearances: Preliminary Observations Related to 

Backlogs and Delays in Determining Security Clearance Eligibility for 

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

(351884)
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