Security and Suitability 

Process Reform 

December 2008 

Provided by the Joint Security and 

Suitability Reform Team 

EXECUTIVE OFFICE OF THE PRESIDENT
 

OFFICE OF MANAGEMENT AND BUDGET
 

WASHINGTON, D.C. 20503
 

DEPUTY DIRECTOR 

FOR MANAGEMENT 

December 17, 2008 

The Honorable George W. Bush 

President ofthe United States 

Washington, DC 

Dear President Bush: 

This is to report on the progress made to improve the timeliness and effectiveness ofour hiring 

and clearing decisions and the specific plan to reform the process further, in accordance with our 

initial proposals made in April ofthis year. 

In 2005, the fastest 90% of security clearance determinations took an average of 265 days to 

complete, ~hich was unsatisfactory. The Intelligence and Terrorism Prevention Act of 2004 

(IRTPA) calls for the fastest 90% of security clearance determinations to be made in 60 days by 

December, 2009, to the extent practicable. This created a target to improve timeliness by 205 

days, 9Q% ofwhich has been accomplished. This detailed plan to improve and reform the 

process further will make it possible to achieve the IRTPA timeliness goal, at a minimum, and 

better ensure the quality ofhiring and clearing decisions. 

The governance structure for this reform effort, the Suitability and Security Clearance 

Performance Accountability Council (PAC), will ensure these reforms are implemented as 

promised. 
December 2008 

EXECUTIVE SUMMARY 

In response to significant, continuing security clearance timeliness concerns, Congress called for 

improvements and established specific timeliness goals as part of the Intelligence Reform and 

Terrorism Prevention Act of 2004 (IRTPA). Since the enactment of IRTPA, average 

timeliness for 90 percent of all clearance determinations reported has been substantially 

improved, from 265 days (in 2005) to 82 days (4th Quarter, Fiscal Year (FY) 2008). These 

performance gains have been realized primarily as a result of increased investigative and 

adjudicative capacity, and increased accountability for performance. 

To further improve timeliness and achieve the IRTPA goal of 60 days or better, a transformed 

process for making hiring and clearing determinations has been designed, as first described in the 

Initial Report on Security and Suitability Process Reform, dated April 30, 2008. This process will 

leverage modern tools and technologies, yet still yield the quality of information needed to make 

these determinations. Progress toward, and future plans for, implementing the transformed 

process are detailed in this report, including: 

Foundational policy changes needed to ensure reform takes root and is sustained. This 

includes Executive Order 13467, signed June 30, 2008, and a December 2008 revision to the 

Federal Investigative Standards that changes the ground rules by which background 

investigations are performed. 

The establishment of a governance structure for this reform effort, the Suitability and 

Security Clearance Performance Accountability Council (PAC), to ensure these reforms are 

adopted and put into operation as planned. The PAC will hold agencies accountable for the 

timeliness of their determinations, and ensure all stakeholders are kept informed as to the 

progress of the reform effort. 

An Information Technology (IT) strategy that focuses on utilizing existing systems and 

applications within the Federal Government, modifying and adapting the systems and 

applications to create a framework for future phased implementation. This approach will 

enable near term implementation, align IT modernization plans with the transformed 

process, and enable the use of components to reduce duplication and enhance reciprocity 

while focusing on quality, service, and cost. 

With sustained leadership attention and commitment, these reforms will be substantially 

operational across the Federal Government by the end of Calendar Year (CY) 2010, with plans to 

begin phased implementation in 2009. These plans, in conjunction with improvements made to 

date, provide the confidence to project that we will meet the December 2009 goal of making 

initial hiring and clearing determinations in an average 60 days or less. 

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Security and Suitability Process Reform 

INTRODUCTION 

The Joint Security and Suitability Reform Team (Joint Reform Team) Initial Report on 

Security and Suitability Process Reform, dated April 30, 2008, provided a framework to 

make the hiring and clearing processes even more timely and efficient. The framework 

aligns suitability and security clearance processes, enabling the application of consistent 

standards and the reciprocal recognition of investigations. 

This report highlights key reform milestones and outlines future activities and their expected 

implementation timeframes. It also documents progress toward meeting Intelligence Reform 

and Terrorism Prevention Act of 2004 (IRTPA) timeliness requirements. 

KEY ENABLERS OF REFORM 

Security clearance and suitability reform requires not only the technological and process 

refinements to conduct hiring and clearing decisions more quickly and efficiently, but also the 

leadership structure and oversight authority to carry the reform efforts through to its intended 

vision. The three key enablers of reform necessary to create the foundation for the transformed 

system and ensure its success are: an effective Federal governance structure; revised Federal 

Investigative Standards; and an integrated Enterprise Information Technology (IT) Strategy. 

Governance. The April 2008 Report recommended that an Executive Branch governance 

structure is needed to ensure the hiring and clearing processes are effectively coordinated across 

the government. The necessary structure is provided by Executive Order 13467, Reforming 

Processes Related to Suitability for Government Employment, Fitness for Contractor 

Employees, and Eligibility for Access to Classified National Security Information, which was 

signed on June 30, 2008. 

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December 2008 

Executive Order 13467 established an executive agent to oversee investigations and 

adjudications for employment suitability, and another to have the corresponding role for 

security clearances. OPM became the Suitability Executive Agent, continuing its 

statutory responsibilities over suitability matters, and the Director of National 

Intelligence was named the Security Executive Agent, and will be responsible for 

overseeing investigations and determinations of eligibility for access to classified 

information. Executive Order 13467 also established a Federal-level Suitability and 

Security Clearance Performance Accountability Council (PAC), responsible to the 

President for achieving reform goals, ensuring alignment, measuring agency 

performance, holding agencies accountable for implementation, and establishing 

information technology requirements. 

The PAC established two standing subcommittees. The Performance Measurement and 

Management Subcommittee is responsible for establishing government-wide metrics that 

measure quality, timeliness, and reciprocity for investigations and adjudications. The 

Training Subcommittee is responsible for establishing core competencies for security 

clearance and suitability professionals, and developing standardized training and 

certification programs. The PAC and its subcommittees will continue to steer and 

monitor implementation of reform by the Suitability and Security Executive Agents and 

executive branch agencies. 

Two future initiatives have potential to enhance governance and promote alignment of 

suitability and security processes. One would address reciprocity for agency 

determinations of whether excepted service and contractor employees are fit to perform 

work for or on behalf of the Federal Government based on their character and conduct. 

The other considers requiring reinvestigations of those Federal employees holding 

public trust positions. 

Together, these initiatives will provide the governing foundation to sustain reform 

momentum. The Joint Reform Team will continue to assess whether additional 

executive branch policy or legislative authority is required to steer reform and, if so, 

make recommendations to the Suitability and Security Executive Agents to adopt or 

seek those policies or authorities. 

Federal Investigative Standards. In December 2008, the Director of National 

Intelligence and Director of the Office of Personnel Management approved revised 

Federal Investigative Standards to implement the transformed process design. The 

revised standards will be used for both hiring and clearing investigations and are a vital 

piece of the reform effort. They require the use of automation to the greatest extent 

practicable, both to speed processing and to permit use of new tools. 

3 
 

 

Security and Suitability Process Reform 

Case Flagging Strategy: The revised investigative standards apply a case flagging strategy 

to identify cases with potential issues that require further investigation. This strategy uses 

automated record checks of commercial and government databases, the subject’s 

application, and when required, the subject interview to identify those cases requiring human 

investigation and adjudication. The “clean cases” with no flagged issues will be electronically 

adjudicated (eAdjudicated), which improves timeliness and allows adjudicative resources to 

concentrate on cases where issues are present. 

This transition to automated case flagging in the investigative standards is driven by the 

results of several research efforts. The research showed that the flagging strategy, as 

described, is as effective as traditional field leads at identifying cases with issues. The case 

flagging strategy, in concert with Expandable Focused Investigation (EFI) methods, focuses 

investigative resources on the cases that need additional scrutiny. 

Tiered Investigative Model and Simplified Position Designation Approach: The 

revised investigative standards employ a three-tiered investigative model that aligns the 

investigative requirements for both security clearance and suitability cases according to their 

relative risk. This alignment reduces the types of initial investigations from fifteen to three 

and the types of reinvestigations from five to two. The alignment also eliminates 

customization of investigations, further emphasizing standardization and better enabling 

government-wide reciprocity. The position designation process, used to determine risk and 

sensitivity based on the nature and duties of the position, also was simplified to align with 

the tiered investigative model. These initiatives improve the efficiency of the investigative 

and adjudicative agency infrastructures since investigators, adjudicators, and associated 

policies and processes will no longer have to support numerous specialized requirements. 

4 
 

December 2008 

The new investigative tiers depicted on page 4 align low, moderate, and high risk 

position designations with investigative requirements for determining access to 

classified information. Each successive investigative tier builds on, but does not 

duplicate, the tier below it. Additionally, investigations do not duplicate leads 

previously conducted that do not change over time. Reducing the range of 

investigative levels will simplify the process, focus resources, ensure consistency, and 

support reciprocity. 

Implementation: Adoption of the revised investigative standards is dependent upon 

the availability of automated collection capabilities to support implementation. The 

implementation strategy will provide for incremental deployment in select 

populations beginning in 2009. Initial implementation plans will be complete no later 

than March 2009. Agencies will continue to use the existing investigative standards 

until the implementation of the revised investigative standards. 

Enterprise IT Strategy. Currently, there are many hiring and clearing systems in Relevant data is 

use across the U.S. government. Many of these systems provide similar functionality, but better used for are not interoperable. The IT strategy for the reform effort, scheduled for completion subsequent hiring February 2009, focuses on leveraging the existing systems and applications by modifying or clearing and adapting their capabilities to create a framework for phased implementation. This decisions, reducing approach will enable near-term implementation, align IT modernization plans with the 

duplication of reform vision, reduce duplication, and enhance reciprocity. The strategy recognizes the 

requests and unique requirements of the Intelligence Community (IC), which necessitate operation 

ensuring consistent outside the Federal-civilian and Department of Defense (DoD) populations 

quality and (mainstream). Nevertheless their need to share information and collaborate within the 

standards. larger community means the tools, services, and standards developed for the mainstream 

will be leveraged to the maximum extent possible in the IC environment. 

Each of the seven process design modules that follow is an enterprise capability and 

when integrated together will enable the end-to-end transformed process. The figure on 

pages 13 - 14 summarizes the CY09 implementation timelines. 

PROCESS DESIGN IMPLEMENTATION 

The transformed process design was validated through research and demonstration 

projects. Each step of the transformed design provides opportunities to leverage current 

processes and introduce new capabilities where necessary. These reforms are described 

below in further detail, and highlight the capabilities achieved to date and those planned 

for the future. 

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Security and Suitability Process Reform 

Validate Need focuses on ensuring hiring and clearing requests are tied to mission 

needs by optimizing policy, procedures, and tools to prevent unnecessary 

investigation requests. This design provides a predictable, consistent process whereby 

agencies can validate existing information and only submit individuals to the hiring and clearing 

process as needed. Employers will check the appropriate databases to determine if individuals 

selected for Federal positions or to work as contractor employees have qualifying clearances or 

open investigations that meet current requirements. 

Validate 

Need 

Achievements: Established a single access point to search relevant 

clearance and investigation data via OPM’s enhanced Clearance 

Verification System (CVS) to increase reciprocity of investigations and 

hiring and clearing decisions. 

Sept 08 

2009 Milestones: Further improvements will include a web-based 

platform to increase accessibility and improve access to IC records to 

enhance reciprocity of investigations and clearance determinations. 

Sept 09 

Estimated Operational Date: 2QCY10 

Pre-Application Best Practices: Best practices for reducing errors and identifying common 

mistakes in the application process have been gathered from Government and Industry and 

compiled into a product available to all stakeholders. Through the PAC, recommended standard 

operating procedures will be promoted, and agency performance measured, to reduce submission 

time and improve quality of information available for Investigative Service Providers. 

Single Search Automated Interface for Verification of Existing Investigations: 

Access to investigative and clearance information minimizes duplicate, unnecessary 

investigations, and enables reciprocal recognition of existing favorable suitability 

determinations and security clearances, thereby saving time and money. To support 

information sharing throughout the Federal Government, OPM expanded its CVS in 

September 2008 to include information related to Homeland Security Presidential 

Directive-12 (HSPD-12), suitability for government employment, fitness for excepted 

service and contractor employees and eligibility for access to classified information. The 

September 2009 enhancements will permit an expanded base of users from across 

government to search OPM and DoD data from a single web-based entry point, further 

enabling reciprocity and reducing unnecessary requests for investigations. Forthcoming 

improvements will include greater accessibility of suitability data and increased access to IC 

clearance records. 

6 
 

 

 

 

December 2008 

Automated Solution to Validate Investigations Requested, Conducted, and Costs 

Billed: The Air Force Central Adjudication Facility (CAF) has successfully deployed an 

automated billing tool that enables rapid reconciliation of OPM billing for Air Force 

investigations. This automated solution enables the ability to validate investigations 

requested, evaluate projections for numbers of investigations, and track investigative 

expenditures against available budgets in an end-to-end system. Evaluation is underway 

to deploy the automated billing capability across DoD. 

 eApplication The Electronic Application (eApplication) is a dynamic, interactive, web-based tool 

that guides users in providing additional relevant suitability or security clearance 

information. The eApplication is essential to the success of the transformed end-to-end 

process by ensuring earlier, efficient collection and transmission of information supporting 

investigation requests. 

Achievements: The Enhanced Electronic Questionnaires for Sept 08 Investigations Processing (e-QIP) system was deployed to introduce 

additional branching questions and expand upfront collection of 

information from the user to improve accuracy and quality of data to 

enable electronic flagging of issues. 

2009 Milestones: Implement revised e-QIP designed to be more Dec 09 

interactive and collect more information from the user earlier in the 

process and improve the quality of the data entered. 

Estimated Operational Date: Dec 09

More relevant 

data is collected 

and validated at 

the beginning of 

the process. 

e-QIP: Electronic submission through e-QIP has led to improved processing times for 

all types of investigations and dramatically reduced the overall error and rejection rates 

for completed standard investigative forms. 

Research verified that the investigative questionnaire and the subject interview are 

key sources of relevant issue information that arises during a background 

investigation. The online e-QIP now gathers more information from the subject 

through the use of additional branching questions. The application asks follow-up 

questions as necessary to enhance the collection of relevant subject-reported 

information, facilitating faster hiring and clearing determinations. The questions 

also help flag investigations for the EFI. A more comprehensive suite of branching 

questions will be included in the next-generation of e-QIP, which is targeted for 

deployment in December 2009. 

Other revisions to the investigative questionnaire planned for 2009 include changes 

to the consent form to inform applicants that the information provided could be 

used for research and/or study purposes, and also advises individuals that they will 

7 
 

 

2009, will eliminate the need for hardcopy submissions of signature pages. 

Security and Suitability Process Reform 

be subject to continuous evaluation while they have access to classified 

information or occupy sensitive positions. The PAC will continue to promote 

even greater use of e-QIP by suitability and security stakeholders. 

Electronic and Digital Signatures: Today’s technology enables the collection and 

processing of signatures through digital (unique codes generated in transmission) and 

electronic (captured using a pad and stylus) signatures. The use of these technologies 

on the application and electronic release authorizations, currently planned for February 

Electronic Fingerprints: An essential element of every investigation is the use of Automation is fingerprints to identify criminal history on record with the Federal Bureau of 

used to make the Investigation (FBI). Currently there are hundreds of locations with electronic 

fingerprint scanning stations deployed or soon to be deployed across the Federal process faster, 

Government. Some are used for the suitability or security clearance process; others are reduce manual 

for HSPD-12, immigration, or port security. activity, and 

leverage 

additional data A feasibility study assessing the use of existing and planned fingerprint scanning 

sources. stations across the government to optimize the automation opportunities in processing 

investigative requests will be completed by February 2009. 

Automated 

Record 

Checks (ARC) 

Automated Record Checks (ARC) utilize applicant data to collect relevant 

information available through government and commercial databases. These 

additional sources of information will assist in verifying identity and afford access to 

timely, robust and ever-expanding sets of data that are relevant to hiring and clearing decisions. 

Research validated the use of ARC to flag issues up front, allowing field investigative resources 

to focus on cases with issues. 

The ARC capability will provide automated data collection along with the ability to validate and 

analyze completeness, timeliness and cost of automated leads. It will also provide an 

automated means to derive and initiate additional record checks based on initial results, scope 

field leads (e.g., Local Agency Checks (LACs), employment checks), and filter out records that 

Achievements: Revised Federal Investigative Standards to optimize use of 

commercially available electronic data to streamline the investigative process. 

Dec 08 

2009 Milestones: 

Initial ARC capability fielded to select Department of the Army populations. Jun 09 

Implementation strategy for future ARC capability finalized. Jun 09 

Estimated Operational Date: 3QCY10 

8 
 

 

December 2008 

are not applicable to the subject. Investigative Service Providers will use the results of the 

automated record checks to inform the expandable focused investigation and enhanced subject 

interview, as appropriate. Once implemented, redundant record checks may be discontinued, 

realizing cost savings and efficiencies. 

ARC Initial Operating Capability (IOC): ARC IOC will be achieved in 2009 and 

leverage the existing record check capability at OPM and DoD. OPM’s current record 

check capability taps into prior investigation records, conducts automated fingerprint 

searches, performs credit checks, and reviews other external systems, where electronic 

linkages exist. DoD’s current capabilities include performing record checks using over 30 

commercial and government databases and applying automated identity resolution, issue 

identification, and report generation mechanisms. DoD’s Automated Continuous 

Evaluation System (ACES), which is currently deployed in a limited test environment, 

could be scaled to meet the Federal requirements. These services, in conjunction with the 

revised investigative standards, will be applied to a select population that includes both 

DoD and non-DoD security and suitability cases in 2009. Additional populations will be 

phased in as the ARC capability is expanded. 

eAdjudication Electronic adjudication (eAdjudication) is a viable technical means to automatically, 

electronically render hiring and clearing determinations in cases with no actionable 

issues. Approximately 25 percent of all Secret cases can be favorably eAdjudicated by 

applying computer coded business rules to the adjudicative decision process. The use of 

eAdjudication procedures improves timeliness, ensures consistent “clean cases” decisionmaking, and allows adjudicators to focus on cases where issues have been identified. Executive 

Order 13467 permits the use of “appropriate automated procedures” when determining 

security clearance eligibility within the executive branch departments and agencies. 

Achievements: Clean case eAdjudication for Army cases requiring a Secret 

security clearance demonstrates a reduction in processing time and enables 

the reallocation of adjudicative resources to cases with issues present. 

Nov 08 

2009 Milestones: Phased implementation is planned for clean case 

eAdjudication in DoD Industry, select DoD, and non-DoD, populations to 

improve timeliness and workflow. 

Apr 09 –Dec 09 

Estimated Operational Date: 2QCY10 

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Security and Suitability Process Reform 

In November 2008, DoD issued guidance to implement eAdjudication of Secret clean 

cases within DoD and began implementation with the Army. During this phase, 

Secret clean cases underwent parallel electronic and manual adjudicative processing as 

part of an established audit function. The audit function will evolve into a long-term 

program for continuous assurance and quality control of eAdjudication results. The 

use of eAdjudication will be deployed to non-DoD populations concurrent with 

broader DoD implementation. In April 2009, DoD will implement eAdjudication for 

all Industry Secret clean cases and continue to expand the capability to eAdjudicate all 

DoD Secret clean cases. Business rules, revised issue-codes, and reliable electronic file 

formats are currently being developed to support a broader implementation of 

eAdjudication, to be operable by December 2009. 

Enhanced 

Subject 

Interview 

An Enhanced Subject Interview (ESI) is an in-depth discussion between 

an interviewer and the subject to ensure a full understanding of the 

applicant’s information, potential issues, and mitigating factors. The revised 

investigative standards require an ESI at Tier Three. 

Achievements: Demonstration results validated the utility of a modified, 

interactive approach to interviewing subjects compared to current methods. 

Oct 08 

2009 Milestones: Training Subcommittee to develop curriculum for 

training national security clearance professionals, as well as training 

materials for inclusion in the handbooks for investigators and adjudicators. 

Jun 09 

Estimated Operational Date: 2QCY09 

The ESI will provide a more interactive, in-depth approach to interviewing the subject 

to gain accurate and detailed data. The ESI will focus on flagged issues arising from 

the subject’s application and/or automated record checks as areas of potential 

concern. During the ESI, the subject will also have an opportunity to refute, explain, 

clarify, or mitigate unfavorable information gathered during the investigation. The ESI 

concept was tested in a demonstration which suggested that an ESI may uncover 

issues the subject did not disclose on their application. The results indicated that 

additional detail on self-reported issues could facilitate a more complete 

understanding of those issues and better inform the hiring or clearance decision. Field investigative 

activity is focused 

to collect and 

validate targeted 

information. 

10 
 

 

December 2008 

An Expandable Focused Investigation (EFI) is an in-depth field investigation of 

potential issues as reported by the subject or found through ARC. This approach is 

an alternative to today’s requirement to pursue all lead types in all cases. EFI focuses 

investigative field leads on potential issue cases detected but not resolved by information previously 

collected. By analyzing case facts that have been reported in the eApplication, ARC, and/or the 

ESI, appropriate field leads are performed to collect information required for resolution of issues. 

Discontinuing the practice of routinely pursuing all leads should result in increased process 

Expandable 

Focused 

Investigation 

timeliness and efficiency. The revised investigative standards mandate an EFI at all tiers when 

issue cases are flagged. 

Achievements: The revised Federal Investigative Standards enable the case 

flagging strategy to focus investigative resources to the types of leads that 

will provide the most productive information thereby optimizing 

investigative resources. 

Dec 08 

2009 Milestones: Demonstrate an ARC-enabled EFI on select non-DoD 

populations to determine cost-effectiveness, timeliness, and productivity. 

Dec 09 

Estimated Operational Date: 3QCY10 

Implementation plans for EFI are being developed in tandem with the new case flagging 

strategy. Available systems are currently being examined to perform the initial checks necessary 

to flag cases, and determining which additional investigative elements should be conducted 

when case issues are present. The EFI model will be fully developed by February 2009. 

Continuous 

Evaluation 

Continuous Evaluation (CE) includes an electronic review of scheduled updates of 

a subject’s application information, ARC, and an electronic assessment of the 

information acquired. CE will ascertain on a more frequent basis whether an eligible 

employee with access to classified information continues to meet the requirements for access. 

The revised investigative standards replace the periodic reinvestigation model with CE annually 

Achievements: 

Issued for public comment the revised ‘consent’ portion of the Oct 08 

application (SF-86) to inform applicants of CE. 

Revised Federal Investigative Standards from the current 5, 10, and 15 Dec 08 

year field reinvestigative cycle to manage risk by evaluating cleared 

population more frequently. 

2009 Milestones: Develop Implementation Plan to transition from Jun 09 

periodic reinvestigations to CE. 

Estimated Operational Date: 3QCY10 

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Security and Suitability Process Reform 

for Tier Three (Top Secret or high risk positions) and at least once every five years 

for Tier Two (Secret, Confidential, or moderate risk positions). This will 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. 

IMPLEMENTATION TIMELINE 

The reforms described above are part of a comprehensive, phased implementation 

plan beginning in September 2008 (shown on pages 13 - 14). Much of what is Continuous 

planned relies on IT to incrementally achieve capabilities needed to enable the evaluation 

transformed process. For example, an end-to-end IT process demonstration was techniques rely on 

conducted to perform clearance investigations for “live cases” on Secret and Top modern analytic 

Secret applicants within the Department of the Army. The results of the methods rather 

demonstration support the approach to leverage existing capabilities to achieve than practices that near-term results. Over time, the end-to-end transformed process will be available avoid risk. throughout the Federal Government to support hiring and clearing decisions more 

efficiently and effectively. 

Resource Considerations. Resources from DoD and OPM should be sufficient 

to enable implementation of the transformed process design for the mainstream 

elements of the process. Funding has been identified by each of these entities to 

support planned reforms as the upgrades are implemented in phases. In addition, 

existing system modernization plans will be reviewed to ensure alignment with the 

transformed vision and to avoid investments in systems and processes that are 

inconsistent with the overall reform vision. These resources are not intended to 

cover any costs associated with respective agency IT modifications that may be 

necessary. Agency IT modernization plans should be consistent with the end-toend automation framework and architecture as approved by the PAC. 

12 
December 2008 

13 
Security and Suitability Process Reform 

14 
 

December 2008 

PERFORMANCE MANAGEMENT 

The IRTPA established goals and performance measures for security clearances only. Under the 

direction of the PAC, the Performance Measurement and Management Subcommittee 

(Performance Subcommittee) is increasing the scope of performance measurement to include 

suitability determinations. The Performance Subcommittee is also establishing standardized 

metric definitions, and performance collection and reporting processes. In addition to IRTPAdefined categories the Performance Subcommittee has established the following definitions: 

End-to-End Time: the time from the date of submission by the applicant to the date of 

adjudicative decision; 

Initiate Time: the time from the date of submission by the applicant to the receipt date of all 

information/forms (PSI forms, releases, fingerprint cards, etc.) required to conduct an 

investigation by the investigative service provider; 

Investigative Time: the time from the receipt date of the completed personnel security 

package (PSI forms, releases, fingerprint cards, etc.) to the date the adjudicative unit receives 

the complete investigative product; and 

Adjudicative Time: the time from receipt date of the final report of investigation to the date 

of the adjudicative decision. 

Metrics Collection. In addition to standardizing metric definitions, the Performance 

Subcommittee is establishing standard performance definitions for use in metrics collection. 

Some data is currently available in existing systems, while others will require significant agency 

changes to collect. Key components of the metrics criteria include: 

Timeliness: The average number of calendar days to complete the end-to-end process along 

with each subcomponent. Metrics collection for “initiate”, “investigate” and “adjudicate” 

measures can be accomplished in the near-term. 

Inventory/ Work In Progress (WIP): A normalized metric that provides trend data and 

permits forecasting of each agency’s ability to meet goals based on current performance and 

workload. A target (number of weeks of work) will be set for both investigation and 

adjudication processes. A measure in excess of that target indicates a negative trend and 

backlog growth. 

Quality: Measurements for both investigative and adjudicative quality will be collected. 

Investigative quality will be captured in two metrics: (1) the number of deficient 

investigations returned by the customer and accepted by the Investigative Service 

Provider; and (2) the validated results of an investigative product survey to be completed 

by the adjudicator. The Performance Subcommittee will initiate use of the performance 

data gathering tool in the 1st Quarter of CY09. 

The Performance Subcommittee will develop a similar tool to measure adjudicative quality 

and begin use in 2009. 

15 
 

 

means to measure post-adjudication notification time. Collection of “notify” measures will need to be 

accomplished through major changes to the current systems, which is a long-term goal. The 

Performance Subcommittee will also develop measures and goals for reinvestigations to make sure that 

timeliness measures are captured during each phase of the hiring and clearing process. 

Performance Goals for December 2009. The IRTPA states that by December 2009 agencies 

are to complete 90 percent of security clearance determinations in 60 days (investigations in 40 days and 

adjudications in 20 days), to the extent practicable. The Performance Subcommittee expanded the endto-end definition in an effort to further capture the entire process from an applicant’s perspective. 

Security and Suitability Process Reform 

Reciprocity: The initial measures of reciprocity will identify two equally important areas of agency’s 

non-compliance with policy: (1) agencies requesting applicants to complete personnel security 

questionnaires when they have a current security clearance; and (2) an agency’s efforts to request a 

new investigation when there is a current existing investigation within scope. Initially both metrics 

will be collected by each agency in an automated fashion by OPM with the results being forwarded 

to the Security Executive Agent for analysis and validation. The results will be addressed during 

frequent oversight assessments. Reciprocity measures for suitability will also be developed. 

The Performance Subcommittee will continue to refine current definitions, as necessary, to ensure all 

components of the investigative and adjudicative process are measured. This includes establishing the 

Initial Security Clearances and Suitability Determinations 

Initiate Complete within 14 days 

Investigation Complete within 40 days 

Delivery Shared between Investigation and Adjudication 

Adjudication Complete within 20 days 

Total End-to-End 90% complete within 74 days 

Performance Oversight: Following the guidance of Executive Order 13467, the Security and 

Suitability Executive Agents are monitoring the timeliness and quality of all agencies that conduct 

investigations and/or that make suitability and security clearance determinations. The oversight 

assessments results will be presented to the PAC. 

In addition, the Security and Suitability Executive Agents will oversee and assess agencies that 

conduct both security clearance and suitability investigations along with adjudication determinations. 

With a combination of surveys and on-site audits, the Security Executive Agent will closely monitor 

compliance with IRTPA processing goals and future performance requirements. 

16 
December 2008 

A national report card will be developed to clearly report investigative and adjudicative 

performance by all agencies. In addition to displaying all applicable metrics, the report card will 

inform Agency heads of their organization’s performance. This will enable agencies to quickly 

acknowledge processing shortfalls or recognize their agency’s quality of performance processing. 

TRAINING AND CERTIFICATION 

Quality is as important to investigations and adjudications as timeliness. A critical first step toward 

improving quality is to ensure that those doing the day-to-day investigative and adjudicative work 

are properly trained and appropriately certified. Toward that end, the PAC’s Training 

Subcommittee has examined existing training programs and has begun working with member 

agencies to identify core competencies to be mastered by every investigator and adjudicator. These 

core competencies, once established as national standards, will provide the foundation for three 

separate training curricula— one each for the roles of investigators, suitability adjudicators, and 

security clearance adjudicators. The Training Subcommittee expects to develop distinct training 

tracks for each role, as well as a core course common to all. The training would support a 

formalized certification for each role upon completion, by both new professionals as well as those 

already on the job. 

The Training Subcommittee plans to complete the final draft of core competencies in the 1st 

Quarter of CY09, and to finalize curricula for the common core course, as well as the three-track 

training program in the 2nd Quarter of CY09. The strategy and timeline for certifying existing 

investigators and adjudicators will be developed by the 3rd Quarter of CY09. The Training 

Subcommittee will periodically examine the three career paths to ensure continuous improvement in 

the training and certification process. 

17 
Security and Suitability Process Reform 

CONCLUSION 

Reform efforts to date, concentrating on increased capacity and accountability, have achieved 

90 percent of the IRTPA-mandated improvement in timeliness. However, in order to reach and 

potentially exceed IRTPA guidelines, the transformed process must be operationalized. 

Essential institutional changes have been made to both enable that transformation and achieve 

the critically important step of aligning related security clearance and suitability activities. Most 

notably, these changes include the establishment of a Federal-level governing body to oversee 

reform and drive its implementation and necessary policy changes enacted with the revision of 

the Federal Investigative Standards. These indispensable building blocks, and the leadership 

commitment to implement them, are needed in order to realize the benefits of reform. 

Future process reform efforts, the majority to be placed into operation over the next two years, 

will include a strong focus on delivering near term capability while laying the basis for broad, 

long-term implementation. Successful implementation will require agencies to act with discipline 

and accountability, ensuring execution against the plan and follow up through established 

performance measures. 

18 
 

December 2008 

APPENDIX 

Accountability Through Metrics. IRTPA requires every agency performing either 

security clearance investigations or adjudications to be responsive to new national security 

clearance processing standards. All agencies must, to the extent practicable, be compliant with 

these performance standards by December 2009. To assist the agencies in projecting workload 

and resource requirements to be compliant with IRTPA, the Office of Management and Budget 

(OMB) issued interim government-wide processing goals for security clearances. Extensive 

metrics collection by OPM and the DNI monitored the investigation and adjudication timeliness 

of the government. The OMB goals for calendar year 2008 were as follows: 

Security Clearance Initial Investigations Reinvestigations 

Submission 15 Days 15 Days 

Investigation: 90% complete within 65 days 90% complete within 150 days 

Adjudication: 90% complete within 25 days 90% complete within 30 days 

Total End-to-End 105 days 195 days 

Performance to Date. Significant improvements in security clearance investigations and 

adjudications performance have been achieved over time through increases in investigative and 

adjudicative capacity, process improvements, and greater accountability. The charts below 

depict the performance improvements from 2006 through 2008, and for the 4th Quarter of FY 

2008. This data indicates trends towards meeting the goals defined by IRTPA. 

19 
Security and Suitability Process Reform 

Although not required by IRTPA, suitability performance data are depicted below. 

20 
 

December 2008 

LIST OF ACRONYMS 

ACES Automated Continuing Evaluation System 

ARC Automated Record Checks 

CAF Central Adjudication Facility 

CE Continuous Evaluation 

CVS Clearance Verification System 

CY Calendar Year 

DNI Director of National Intelligence 

DoD Department of Defense 

DOE Department of Energy 

EFI Expandable Focused Investigation 

e-QIP Electronic Questionnaires for Investigations Processing 

ESI Enhanced Subject Interview 

FBI Federal Bureau of Investigation 

FY Fiscal Year 

HSPD Homeland Security Presidential Directive 

IC Intelligence Community 

IOC Initial Operating Capability 

IRTPA Intelligence Reform and Terrorism Prevention ACT of 2004 

IT Information Technology 

LAC Local Agency Check 

OMB Office of Management and Budget 

OPM Office of Personnel Management 

PAC Suitability and Security Clearance Performance Accountability Council 

PSI Personnel Security Investigation 

SF-86 Standard Form 86 

WIP Work In Progress 

21