PERSONNEL 

SECURITY 

CLEARANCES

Opportunities Exist to 

Improve Quality 

Throughout the 

Process

Statement of Brenda S. Farrell, Director

Defense Capabilities and Management

Testimony

Before the Subcommittee on 

Counterterrorism and Intelligence, 

Committee on Homeland Security, 

U.S. House of Representatives

For Release on Delivery 

Expected at 2:00 p.m. EST

Wednesday, November 13, 2013

GAO-14-186T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-186T, a testimony 

before the Subcommittee on Counterterrorism 

and Intelligence, Committee on Homeland 

Security, U.S. House of Representatives

November 13, 2013

PERSONNEL SECURITY CLEARANCES

Opportunities Exist to Improve Quality Throughout 

the Process

Why GAO Did This Study

In 2012, the DNI reported that more 

than 4.9 million federal government 

and contractor employees held or were 

eligible to hold a personnel security 

clearance. Furthermore, GAO has 

reported that the federal government 

spent over $1 billion to conduct more 

than 2 million background 

investigations in fiscal year 2011. A 

high quality process is essential to 

minimize the 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. Security clearances may 

allow personnel to gain access to 

classified information that, through 

unauthorized disclosure, can in some 

cases cause exceptionally grave 

damage to U.S. national security.

Recent events, such as unauthorized 

disclosures of classified information,

have illustrated the need for additional 

work to help ensure the process

functions effectively and efficiently.

This testimony addresses the (1) roles 

and responsibilities of different 

executive branch agencies involved in

the personnel security process; (2) 

different phases of the process; and (3) 

extent that agencies assess the quality 

of the 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, executive 

orders, guidance, and processes; (2) 

examined agency data on timeliness 

and quality; (3) assessed reform 

efforts; and (4) reviewed samples of 

case files for DOD personnel.

What GAO Found

Several agencies in the executive branch have key roles and responsibilities in 

the personnel security clearance process. Executive Order 13467 designates the 

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

responsible for developing policies and procedures for background investigations 

and adjudications. The Office of Personnel Management (OPM) conducts

investigations for most of the federal government. Adjudicators from agencies, 

such as the Departments of Defense (DOD) and Homeland Security, that request 

background investigations use the investigative report and consider federal 

adjudicative guidelines when making clearance determinations. Reform efforts to 

enhance the personnel security process throughout the executive branch are

principally driven and overseen by the Performance Accountability Council, which 

is chaired by the Deputy Director for Management at the Office of Management 

and Budget (OMB).

Executive branch agencies rely on a multi-phased personnel security clearance 

process that includes requirements determination, application, investigation, 

adjudication, appeals (if applicable, where a clearance has been denied), and 

reinvestigation (for renewal or upgrade of an existing clearance). In the 

requirements determination phase, agency officials must determine whether 

positions require access to classified information. After an individual has been 

selected for a 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. If a clearance is denied or 

revoked by an agency, appeals of the adjudication decision are possible. 

Individuals granted clearances are subject to reinvestigations at intervals that are 

dependent on the level of security clearance.

Executive branch agencies do not consistently assess quality throughout the 

security clearance process, in part because they have not fully developed and 

implemented metrics to measure quality in key aspects of the process. For 

example, GAO reported in May 2009 that, with respect to initial top secret 

clearances adjudicated in July 2008 for DOD, documentation was incomplete for 

most of OPM’s investigative reports. GAO also estimated that 12 percent of the 

3,500 reports did not contain the required personal subject interview. To improve 

the quality of investigative documentation, GAO recommended that OPM 

measure the frequency with which its reports met federal investigative standards. 

OPM did not agree or disagree with this recommendation, and as of August 2013

had not implemented it. Further, GAO reported in 2010 that agencies do not 

consistently and comprehensively track 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 agency. OPM created a metric in early 2009 to track reciprocity, but 

this metric does not track how often an existing security clearance was 

successfully honored. GAO recommended that OMB develop comprehensive 

metrics to track reciprocity. OMB agreed with the recommendation, but has not 

yet fully implemented actions to implement this recommendation.

View GAO-14-186T. For more information, 

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

FarrellB@gao.gov.
Page 1 GAO-14-186T 

Chairman King, Ranking Member Higgins, and Members of the 

Subcommittee:

Thank you for the opportunity to be here to discuss the quality of the 

federal government’s personnel security clearance process. 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,1 posing formidable challenges to those 

responsible for deciding who should be granted a clearance. Personnel 

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 a military, federal 

civilian, or contractor employee 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. We have reported that 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 2011.2

A high-quality process is essential in order to minimize the 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. Security clearances may allow personnel to gain 

access to classified information that, through unauthorized disclosure, 

can in some cases cause exceptionally grave damage to U.S. national 

security. Recent events, such as unauthorized disclosures of classified

information, have illustrated both the potential consequences of such 

disclosures and the need for additional work on the part of federal 

agencies to help ensure the process functions effectively and efficiently, 

 1

Office of the Director of National Intelligence, 2012 Report on Security Clearance 

Determinations (January 2013). 

2

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

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

28, 2012).
Page 2 GAO-14-186T 

so that only trustworthy individuals obtain and keep security clearances 

and the resulting access to classified information that clearances make 

possible. 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 Department of Defense’s (DOD) clearance 

program and the government-wide effort to reform the security clearance 

process, and have reported repeatedly on the need to build quality into 

the process.

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

clearances: (1) the roles and responsibilities of the different executive 

branch agencies involved in the personnel security clearance process, 

(2) the different phases of the security clearance process that are typically 

followed by most executive branch agencies, and (3) the extent that 

executive branch agencies assess the quality of the security clearance 

process during these different phases.

This 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 relevant statutes and executive 

orders, federal guidance, and processes; examined agency personnel 

security clearance policies; 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. Further, as part of our ongoing effort to determine the status of 

agency actions to address our prior recommendations, we reviewed the 

current proposal to revise a relevant federal regulation regarding position 

designation.

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. Additional details about the 

scope and methodology can be found in each of these related products.
Page 3 GAO-14-186T 

Several agencies in the executive branch have key roles and 

responsibilities in the federal government’s personnel security clearance 

process. In a 2008 memorandum, the President called for a reform of the 

security clearance and suitability determination processes and 

subsequently issued Executive Order 13467,3

Further, Executive Order 13467 established a Suitability and Security 

Clearance Performance Accountability Council, commonly called the 

Performance Accountability Council, that is accountable to the President 

for achieving the goals of the reform effort, which include an efficient, 

practical, reciprocal, and aligned system for investigating and determining 

eligibility for access to classified information. Under the executive order, 

this council is responsible 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 (OMB) as the 

chair of the council.

which designates the 

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

such, the DNI is responsible for developing policies and procedures to 

help ensure the effective, efficient, 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. 

Positions designated as sensitive are any positions within a department 

or agency where the occupant could bring about, by virtue of the nature of 

the position, a material adverse effect on national security.

4

 3

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). 

In addition, the executive order states that agency 

heads shall assist the Performance Accountability Council and executive 

agents in carrying out any function under the order, as well as 

implementing any policies or procedures developed pursuant to the order.

4

The 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.

Agencies’ Roles and 

Responsibilities in the 

Personnel Security 

Clearance Process
Page 4 GAO-14-186T 

Executive branch agencies that request background investigations use 

the information from investigative reports to determine whether an 

applicant is eligible for a personnel security clearance. Two of the 

agencies that grant the most security clearances are DOD and the 

Department of Homeland Security (DHS). DOD accounts for the majority 

of all personnel security clearances, and spent $787 million on suitability 

and security clearance background investigations in fiscal year 2011.5

Investigators—often contractors—from Federal Investigative Services 

within the Office of Personnel Management (OPM)6 conduct the 

investigations for most of the federal government.7 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 DOD portion of the National Industrial Security 

Program8

 5

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

Transparency of Its Pricing and Seek Cost Savings, 

for the DOD components and other federal agencies by 

GAO-12-197 (Washington, D.C.: Feb. 

28, 2012). 

6

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.

7

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. 

8

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).
Page 5 GAO-14-186T 

agreement, as well as providing security education and training, among 

other things.

DHS spent more than $57 million on suitability and security clearance 

background investigations in fiscal year 2011. Within DHS, the Chief 

Security Officer develops, implements, and oversees the department’s 

security policies, programs, and standards; delivers security training and 

education to DHS personnel; and provides security support to the DHS 

components. The Chief of DHS’s Personnel Security Division, under the 

direction of the Chief Security Officer, has responsibility for personnel 

security and suitability policies, programs, and standards, including 

procedures for granting, denying, and revoking access to classified 

information as well as initiating and adjudicating personnel security and 

suitability background investigations and periodic reinvestigations of 

applicants. Within the DHS components, the component Chief Security

Officers implement established personnel security directives and policies 

within their respective components.

The personnel security clearance process has also been the subject of 

congressional oversight and statutory reporting requirements. Section 

3001 of the Intelligence Reform and Terrorism Prevention Act of 20049

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 report annually on its timeliness 

expired in 2011. More recently, the Intelligence Authorization Act of 

201010 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.11

 9

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

The Intelligence Authorization Act of 2010 

10Pub. L. No. 111-259, § 367 (2010) (codified at 50 U.S.C. § 3104). 

11This 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 6 GAO-14-186T 

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.

To help ensure the trustworthiness and reliability of personnel in positions 

with access to classified information, executive branch agencies rely on a 

personnel security clearance process that includes multiple phases: 

requirements determination, application, investigation, adjudication, 

appeals (if applicable, where a clearance has been denied), and 

reinvestigation (where applicable, for renewal or upgrade of an existing 

clearance). Figure 1 illustrates the steps in the personnel security 

clearance process, which is representative of the general process 

followed by most executive branch agencies and includes procedures for 

appeals and renewals. While different departments and agencies may 

have slightly different personnel security clearance processes, the phases 

that follow are illustrative of a typical process.12

 12The 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. 

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.

Phases of the 

Personnel Security 

Process
Page 7 GAO-14-186T 

Figure 1: Phases of 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 8 GAO-14-186T 

Executive branch agencies first determine which of their positions—

military, civilian, or private-industry contractors—require access to 

classified information and, therefore, which people must apply for and 

undergo a personnel security clearance investigation. This involves 

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.13 The 

level of classification denotes the degree of protection required for 

information and the amount of damage that unauthorized disclosure could 

reasonably be expected to cause to national defense.14

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. A high 

volume of clearances continue to be processed and a sound 

requirements determination process is needed to effectively manage 

costs, since agencies spend significant amounts annually on national 

security and other background investigations. In addition to cost 

implications, limiting the access to classified information and reducing the 

associated risks to national security underscore the need for executive 

branch agencies to have a sound process to determine which positions 

require a security clearance.

Agency heads are responsible for designating positions within their 

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

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

 13A 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. 

14Unauthorized disclosure could reasonably be expected to cause (1) “damage,” in the 

case of confidential information; (2) “serious damage,” in the case of secret information; 

and (3) “exceptionally grave damage,” in the case of top-secret information. Exec. Order 

No. 13526, 75 Fed. Reg. 707 (Dec. 29, 2009).

Requirements 

Determination Phase
Page 9 GAO-14-186T 

on national security.15 In addition, Executive Order 12968, issued in 1995, 

makes the heads of agencies—including executive branch agencies and 

the military departments—responsible for establishing and maintaining an 

effective program to ensure that access to classified information by each 

employee is clearly consistent with the interests of national security. This 

order also states that, subject to certain exceptions, eligibility for access 

to classified information shall only be requested and granted on the basis 

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

5 of the Code of Federal Regulations provides requirements and 

procedures for the designation of national security positions, which 

include positions that (1) involve activities of the government that are 

concerned with the protection of the nation from foreign aggression or 

espionage, and (2) require regular use of or access to classified national 

security information.16

Part 732 of Title 5 of the Code of Federal Regulations also states that 

most federal government positions that could bring about, by virtue of the 

nature of the position, a material adverse effect on national security must 

be designated as a sensitive position and require a sensitivity level 

designation. The sensitivity level designation determines the type of 

background investigation required, with positions designated at a greater 

sensitivity level requiring a more extensive background investigation. Part 

732 establishes three sensitivity levels—special-sensitive, criticalsensitive, and noncritical-sensitive—which are described in figure 2. 

According to OPM, positions that an agency designates as specialsensitive and critical-sensitive require a background investigation that 

typically results in a top secret clearance. Noncritical-sensitive positions 

typically require an investigation that supports a secret or confidential 

clearance. OPM also defines non-sensitive positions that do not have a 

national security element, and thus do not require a security clearance, 

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

 15Sensitivity level is based on the potential of the occupant of a position to bring about a 

material adverse effect on national security. Some factors include whether the position 

requires access to classified information or involves the formulation of security-related 

policy. The sensitivity level of a position then informs the type of background investigation 

required of the individual in that position. The relationship between sensitivity and resulting 

clearances is detailed in Figure 2.

16Those requirements in Part 732 apply to national security positions in the competitive 

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

executive branch, and certain excepted service positions.
Page 10 GAO-14-186T 

informs the type of investigation required for those positions. Those 

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

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

Figure 2 illustrates the process used by both DOD and DHS to determine 

the need for a personnel security clearance for a federal civilian position 

generally used government-wide.
Page 11 GAO-14-186T 

Figure 2: Typical Security Clearance Determination Process for Federal Civilian Positions in the Departments of Defense and 

Homeland Security

a

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

secret clearance (including Sensitive Compartmented Information) and includes a review of the 

locations where an individual has lived, attended school, and worked. In addition, an SSBI includes 

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

spouses, and a financial record check.

b

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

federal employees at the confidential and secret access levels. It consists of employment checks, 
Page 12 GAO-14-186T 

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

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

Investigation’s investigative index.

c

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

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

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

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. To determine whether an 

investigation would be required, the agency requesting a security

clearance investigation conducts a check of existing personnel security 

databases to determine whether there is an existing security clearance 

investigation underway or whether the individual has already been 

favorably adjudicated for a clearance in accordance with current 

standards. If such a security clearance does not exist for that individual, 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) to the individual to 

complete using OPM’s electronic Questionnaires for Investigations 

Processing (e-QIP) system or a paper copy; (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. 

Application Phase

Investigation Phase
Page 13 GAO-14-186T 

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 requesting agencies for their 

internal adjudicators. 

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

Security Clearance

Type of background 

investigation

Type of information gathered by component 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 M X

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

supervisors and coworkers M X

10. 1References: Data from interviews with subject-identified and investigator-developed leads M 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 M 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 X a

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.

M = Components with this notation are checked through requests for information sent by OPM’s 

Federal Investigative Services through the mail.

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 
Page 14 GAO-14-186T 

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.

In December 2012, the Office of the Director of National Intelligence 

(ODNI) and OPM jointly issued a revised version of the federal 

investigative standards for the conduct of background investigations for 

individuals that work for or on behalf of the federal government. According 

to October 31, 2013 testimony by an ODNI official, the revised standards 

will be implemented through a phased approach beginning in 2014 and 

continuing through 2017.17

During the adjudication phase, adjudicators from the hiring agency use 

the information from the investigative report along with federal 

adjudicative guidelines to determine whether an applicant is eligible for a 

security clearance.18

 17Brian A. Prioletti, Assistant Director, Special Security Directorate, National 

Counterintelligence Executive, Office of the Director of National Intelligence, Statement for 

the Record: Open Hearing on Security Clearance Reform, testimony before the Senate 

Committee on Homeland Security and Governmental Affairs, 113th Cong., 1st sess., 

October 31, 2013.

To make clearance eligibility decisions, the 

adjudicative 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 

18For 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) U.S. 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.

Adjudication and Appeals 

Phases
Page 15 GAO-14-186T 

permit granting a clearance.19

If a clearance is denied or revoked, appeals of the adjudication decision 

are generally possible. We have work underway to review the process for 

security clearance revocations. We expect to issue a report on this 

process in the spring of 2014.

The adjudication process is a careful 

weighing of a number of variables, to include disqualifying and mitigating 

factors, known as the “whole-person” concept. For example, when a 

person’s life history shows evidence of unreliability or untrustworthiness, 

questions can arise as to whether the person can be relied on and trusted 

to exercise the responsibility necessary for working in a secure 

environment where protecting national security is paramount. As part of 

the adjudication process, the adjudicative guidelines require agencies to 

determine whether a prospective individual meets the adjudicative criteria 

for determining eligibility, including personal conduct and financial 

considerations. If an individual has conditions that raise a security 

concern or may be disqualifying, the adjudicator evaluates whether there 

are other factors that mitigate such risks (such as a good-faith effort to 

repay a federal tax debt). On the basis of this assessment, the agency 

may make a risk-management decision to grant the security-clearance 

eligibility determination, possibly with a warning that future incidents of a 

similar nature may result in revocation of access.

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 

 19Federal 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.

Reinvestigation Phase
Page 16 GAO-14-186T 

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 Team20 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 revised federal investigative standards state that the top

secret level of security clearances may be subject to continuous 

evaluation.

Executive branch agencies do not consistently assess quality throughout 

the personnel security clearance process, in part because they have not 

fully developed and implemented metrics to measure quality in key 

aspects of 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, we 

have emphasized, since the late 1990s,21 the need to build and monitor 

quality throughout the personnel security clearance process. While our 

work historically was focused on DOD, particularly since we placed 

DOD’s personnel security clearance program on our high-risk list22 in 

2005 because of delays in completing clearances,23

 20In 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.

we have included 

21GAO, DOD Personnel: Inadequate Personnel Security Investigations Pose National 

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

22Every 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. 

23GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.: Jan. 1, 2005).

Agencies Do Not 

Consistently Assess 

Quality Throughout 

the Personnel 

Security Clearance 

Process
Page 17 GAO-14-186T 

DHS in our most recent reviews of personnel security clearance issues. 

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.

In July 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 personnel security 

clearance, or established guidance to require agencies to review and 

revise or validate existing federal civilian position designations.24

In the absence of clear guidance, agencies are using a position 

designation tool that OPM designed to determine the sensitivity and risk 

levels of civilian positions that, in turn, inform the type of investigation 

needed.

As a 

result, we concluded that DHS and DOD, along with other executive 

branch agencies, do not have reasonable assurance that security 

clearance position designations are correct, which could compromise 

national security if positions are underdesignated, or create unnecessary 

and costly investigative coverage if positions are overdesignated.

25 This tool—namely, the Position Designation of National 

Security and Public Trust Positions—is intended to enable a user to 

evaluate a position’s national security and suitability requirements so as 

to determine a position’s sensitivity and risk levels, which in turn dictate 

the type of background investigation that will be required for the individual 

who will occupy that position. Both DOD and DHS components use the 

tool. In addition, DOD issued guidance in September 201126 and August 

201227

 24GAO, Security Clearances: Agencies Need Clearly Defined Policy for Determining 

Civilian Position Requirements, 

requiring its personnel to use OPM’s tool to determine the proper 

position sensitivity designation. A DHS instruction requires personnel to 

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

25According to OPM’s Federal Investigations Notice No. 10-06, Position Designation 

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

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

excepted service where the incumbent can be noncompetitively converted to the 

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

26DOD, Washington Headquarters Services, Implementation of the Position Designation 

Automated Tool (Sept. 27, 2011).

27DOD Instruction 1400.25, Volume 731, DOD Civilian Personnel Management System: 

Suitability and Fitness Adjudication For Civilian Employees (Aug. 24, 2012).

Guidance Not Developed 

for Determining if 

Positions Require a 

Clearance or for Reviewing 

Existing Position 

Designations
Page 18 GAO-14-186T 

designate all DHS positions—including positions in the DHS 

components—by using OPM’s position sensitivity designation guidance, 

which is the basis of the tool.28

OPM audits, however, have found inconsistency in these position 

designations, and some agencies described problems implementing 

OPM’s tool. For example, during the course of our 2012 review, DOD and 

DHS officials raised concerns regarding the guidance provided through 

the tool and expressed that they had difficulty implementing it. 

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

Enforcement stated that the use of the tool occasionally resulted in 

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

expressed a need for additional clear, easily interpreted guidance on 

designating national security positions. DOD officials stated that they 

have had difficulty implementing the tool because it focuses more on 

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

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

Further, although the DNI was designated as the Security Executive 

Agent in 2008, ODNI officials noted that the DNI did not have input into 

recent revisions of OPM’s position designation tool.

As a result, we recommended that the DNI, in coordination with the 

Director of OPM and other executive branch agencies as appropriate, 

issue clearly defined policy and procedures for federal agencies to follow 

when determining if federal civilian positions require a personnel security 

clearance. In written comments on our July 2012 report, the ODNI 

concurred with this recommendation. In May 2013, ODNI and OPM jointly 

drafted a proposed revision to the federal regulations on position 

designation which, if finalized in its current form, would provide additional 

requirements and examples of position duties at each sensitivity level. We 

also recommended that once those policies and procedures are in place, 

the DNI and the Director of OPM, in their roles as executive agents, 

collaborate to revise the position designation tool to reflect the new 

guidance. ODNI and OPM concurred with this recommendation and 

recently told us that they are in the process of revising the tool.

 28DHS Management Instruction 121-01-007, Department of Homeland Security Personnel 

Suitability and Security Program (June 2009). 
Page 19 GAO-14-186T 

In July 2012, we also reported that the executive branch did not have a 

consistent process for reviewing and validating existing security clearance 

requirements for federal civilian positions.29

DOD’s personnel security regulation and other guidance

According to Executive Order 

12968, the number of employees that each agency determines is eligible 

for access to classified information shall be kept to the minimum required, 

and, subject to certain exceptions, eligibility shall be requested or granted 

only on the basis of a demonstrated, foreseeable need for access. During 

our 2012 review of several DOD and DHS components, we found that 

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

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

requirement to review and validate the security clearance needs of 

existing positions on a periodic basis. We found, instead, that agencies’

policies provided for a variety of practices for reviewing the clearance 

needs of federal civilian positions. In addition, agency officials told us that 

their policies were implemented inconsistently.

30 provides DOD 

components with criteria to consider when determining whether a position 

is sensitive or requires access to classified information, and some DOD 

components also have developed their own guidance. According to DHS 

guidance, supervisors are responsible for ensuring that (1) position 

designations are updated when a position undergoes major changes 

(e.g., changes in missions and functions, job responsibilities, work 

assignments, legislation, or classification standards), and (2) position 

security designations are assigned as new positions are created. Some 

DHS components have additional requirements to review position 

designation more regularly to cover positions other than those newly 

created or vacant. For example, U.S. Coast Guard guidance31

 29

states that 

hiring officials and supervisors should review position descriptions even 

when there is no vacancy and, as appropriate, either revise or review 

them. In addition, according to officials in U.S. Immigration and Customs 

Enforcement, supervisors are supposed to review position descriptions 

GAO-12-800.

30DOD 5200.2-R, Department of Defense Personnel Security Program (January 1987, 

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

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

10, 2011). 

31U.S. Coast Guard, CG-121, Civilian Hiring Guide for Supervisors and Managers, ver. 2 

(June 11, 2010). 
Page 20 GAO-14-186T 

annually during the performance review process to ensure that the duties 

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

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

Enforcement does not have policies or requirements in place to ensure 

any particular level of detail in that review.

During our 2012 review, DOD and DHS officials acknowledged that 

overdesignating a position can result in expenses for unnecessary 

investigations. When a position is overdesignated, additional resources 

are unnecessarily spent conducting the investigation and adjudication of a 

background investigation that exceeds agency requirements. Without a 

requirement to consistently review, revise, or validate existing security 

clearance position designations, we concluded that executive branch 

agencies—such as DOD and DHS—may be hiring and budgeting for both 

initial and periodic security clearance investigations using position 

descriptions and security clearance requirements that do not reflect 

national security needs. Moreover, since reviews were not being done 

consistently, DOD, DHS, and other executive branch agencies did not 

have reasonable assurance that they were keeping to a minimum the 

number of positions that require security clearances on the basis of a 

demonstrated and foreseeable need for access.

Therefore, we recommended in July 2012 that the DNI, in coordination 

with the Director of OPM and other executive branch agencies as 

appropriate, issue guidance to require executive branch agencies to 

periodically review and revise or validate the designation of all federal 

civilian positions. In written comments on that report, the ODNI concurred 

with this recommendation and stated that as duties and responsibilities of 

federal positions may be subject to change, it planned to work with OPM 

and other executive branch agencies to ensure that position designation 

policies and procedures include a provision for periodic reviews. OPM 

stated in its written comments to our report that it would work with the DNI 

on guidance concerning periodic reviews of existing designations.

ODNI and OPM are currently in the process of finalizing revisions to the 

position designation federal regulation. As part of our ongoing processes 

to routinely monitor the status of agency actions to address our prior 

recommendations, we note that the proposed regulation would newly 

require agencies to conduct a one-time reassessment of position 

designations within 24 months of the final regulation’s effective date, 

which is an important step towards ensuring that the current designations 

of national security positions are accurate. However, the national security 

environment and the duties and descriptions of positions may change 
Page 21 GAO-14-186T 

over time, thus the importance of periodic review or validation. The 

proposed regulation, if finalized in its current form, would not require a 

periodic reassessment of positions’ need for access to classified 

information as we recommended. We believe this needs to be done and, 

as part of monitoring the status of our recommendation, we will continue 

to review the finalized federal regulation and any related guidance that 

directs position designation to determine whether periodic review or 

validation is required.

As of August 2013, OPM had not yet implemented metrics to measure the 

completeness of its investigative reports—results from background 

investigations—although we have previously identified deficiencies in 

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.32

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 

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. Officials 

within various executive branch agencies have noted to us that the 

information gathered during the interview and investigative portion of the 

process is essential for making adjudicative decisions.

 32Estimates in our May 2009 report were based on our review of a random sample of 100 

OPM-provided investigative reports for initial top secret clearances granted in July 2008 

by the U.S. Army, U.S. Navy, and U.S. Air Force central adjudication facilities and have 

margins of error, based on a 95 percent confidence interval, of +/- 10 percentage points or 

fewer. 

Quality of OPM 

Investigative Reports Not 

Measured
Page 22 GAO-14-186T 

its investigative reports meet federal investigative standards, so that the 

executive branch can identify the factors leading to incomplete reports 

and take corrective actions.33

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.

OPM did not agree or disagree with our 

recommendation.

34 For example, the 

Rapid Assessment of Incomplete Security Evaluations was one tool the 

executive branch agencies planned to use for measuring quality, or 

completeness, of OPM’s background investigations.35

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 

However, 

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

tool. Instead, OPM stated that it 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.

 33GAO, 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). 

34GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011).

35The 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 23 GAO-14-186T 

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 and timeliness 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 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 of the investigator’s summary. 

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.

To address issues identified in our 2009 report regarding the quality of 

DOD adjudications, DOD has taken some intermittent steps to implement 

measures to determine the completeness of its adjudicative files. In 2009, 

we reported 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.36

 36GAO, DOD Personnel Clearances: Comprehensive Timeliness Reporting, Complete 

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

Clearance Process, 

For example, 

we estimated 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 

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

Some Steps Taken to 

Determine Completeness 

of Adjudicative Files
Page 24 GAO-14-186T 

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.37

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 

on clearances. 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 stated that it restarted the use of RADAR 

in fiscal year 2012.

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.

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 

 37DOD Regulation 5200.2-R, DOD Personnel Security Program (Jan. 1987, incorporating 

changes Feb. 23, 1996).
Page 25 GAO-14-186T 

investigative reports as the basis for granting clearances. This guidance 

provides standards that can be used for the sufficient explanation of 

incomplete investigative reports.

Executive branch agencies have not yet developed and implemented 

metrics to track 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 

agency, although some efforts have been made to develop quality 

metrics. 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; however, we reported in 2010 that 

agencies do not consistently and comprehensively track the extent to 

which reciprocity is granted government-wide.38 ODNI guidance requires, 

except in limited circumstances, that all Intelligence Community elements 

“accept all in-scope39 security clearance or access determinations.”

Additionally, OMB guidance40

 38In 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). 

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 in-scope; (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.

39Although there are broad federal investigative guidelines, the details and depth of an 

investigation varies by agency depending upon its mission. 

40Office 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). 

Extent of Clearance 

Reciprocity Not Measured
Page 26 GAO-14-186T 

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.41

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.

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 

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.

42

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

standardized training and certification process for investigators and 

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.

 41GAO, 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).

42GAO-11-65.
Page 27 GAO-14-186T 

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.43

Consequently, we recommended in 2010 that the Deputy Director of 

Management, OMB, 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.

To achieve fuller reciprocity, clearance-granting agencies 

seek to have confidence in the quality of prior investigations and 

adjudications.

 43GAO, Personnel Clearances: Key Factors to Consider in Efforts to Reform Security 

Clearance Processes, GAO-08-352T (Washington, D.C.: Feb. 27, 2008).
Page 28 GAO-14-186T 

Several efforts are underway to review the security clearance process, 

and those efforts, combined with sustained leadership attention, could 

help facilitate progress in assessing and improving the quality of the 

security clearance process. After the September 16, 2013 shooting at the 

Washington Navy Yard, the President directed the Office of Management 

and Budget, in coordination with ODNI and OPM, to conduct a 

government-wide review into the oversight, nature, and implementation of 

security and suitability standards for federal employees and contractors. 

In addition, in September 2013, the Secretary of Defense directed an 

independent review to identify and recommend actions that address gaps 

or deficiencies in DOD programs, policies, and procedures regarding 

security at DOD installations and the granting and renewal of security 

clearances for DOD employees and contractor personnel. The primary 

objective of this review is to determine whether there are weaknesses in 

DOD programs, policies, or procedures regarding physical security at 

DOD installations and the security clearance and reinvestigation process 

that can be strengthened to prevent a similar tragedy.

As previously discussed, DOD and DHS account for the majority of 

security clearances within the federal government. We initially placed 

DOD’s personnel security clearance program on our high-risk list in 2005 

because of delays in completing clearances.44 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 

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

department’s demonstrated progress in expediting the amount of time 

processing clearances.45

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

from our high-risk list, the Comptroller General noted in June 2012 that 

sustained leadership would be necessary to continue to implement, 

We also noted DOD’s efforts to develop and 

implement tools to evaluate the quality of investigations and 

adjudications.

 44GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.: Jan. 1, 2005).

45GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011).

Recent Efforts and 

Sustained Leadership 

Could Facilitate Progress 

in Assessing Quality
Page 29 GAO-14-186T 

monitor, and update outcome-focused performance measures.46

In conclusion, to avoid the risk of damaging, unauthorized disclosures of 

classified information, oversight of the reform efforts to measure and 

improve the quality of the security clearance process are imperative next 

steps. 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. We will continue to monitor the outcome of the agency 

actions discussed above to address our outstanding recommendations.

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 government-wide challenges remain in ensuring that personnel 

security clearance investigations and adjudications are high-quality. 

However, if the oversight and leadership that helped address the 

timeliness issues focuses now on the current problems associated with 

quality, we believe that progress in helping executive branch agencies to 

assess the quality of the security clearance process could be made.

Chairman King, Ranking Member Higgins, and Members of the 

Subcommittee, this concludes my prepared statement. I would be 

pleased to answer any questions that you or other Members of the 

Subcommittee 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 

this testimony include David E. Moser (Assistant Director), Jim Ashley, 

Renee S. Brown, Ryan D’Amore, and Michael Willems.

 46GAO, Personnel Security Clearances: Continuing Leadership and Attention Can 

Enhance Momentum Gained from Reform Effort, GAO-12-815T (Washington, D.C.: June 

21, 2012).

GAO Contacts and 

Acknowledgment
Related GAO Products

Page 30 GAO-14-186T 

Personnel Security Clearances: Full Development and Implementation of 

Metrics Needed to Measure Quality of Process. GAO-14-157T. 

Washington, D.C.: October 31, 2013.

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.

Related GAO Products
Related GAO Products

Page 31 GAO-14-186T 

DOD Personnel Clearances: Preliminary Observations on DOD’s 

Progress on Addressing Timeliness and Quality Issues. GAO-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. 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.
Related GAO Products

Page 32 GAO-14-186T 

DOD Personnel Clearances: Improved Annual Reporting Would Enable 

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

February 13, 2008.

DOD Personnel Clearances: Delays and Inadequate Documentation 

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

2007.

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.

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