REPORT OF

THE SECURITY CLEARANCE OVERSIGHT GROUP

CONSISTENT WITH

TITLE III OF THE INTELLIGENCE REFORM AND TERRORISM 

PREVENTION ACT OF 2004

FEBRUARY 2007

1

Executive Summary

Government agencies are making significant progress determining security clearance 

eligibility as called for by the Intelligence Reform and Terrorism Prevention Act of 

2004 (IRTPA). Current investigative and adjudicative timeliness for 80% of the 

requests for initial clearances is generally as called for by IRTPA: 90 days or less for 

investigations and 30 days or less for adjudications. 

• For requests for initial security clearances from agencies served by OPM (90% 

of total clearances), we project that the average time for investigations for 80% 

of initial clearances begun after October 1, 2006, plus the average time for 

adjudications for 80% of adjudications begun and reported after October 1, 

2006, will be 120 days or less. 

• 80% of the initial clearance investigations performed by OPM, completed after 

October 1, 2006, averaged 101 days, while 80% of the adjudications by those 

agencies whose investigations are performed by OPM, completed and recorded 

after October 1, 2006, averaged 17 days. The combined averages for 

investigations and adjudications averaged 118 days for 80% of those 

completed after October 1, 2006. 

• ALL investigations completed by OPM after October 1, 2006 averaged 166 

days, while ALL adjudications completed and reported by agencies whose 

investigations are done by OPM, averaged 39 days; so the total of the two 

averages is 205 days. 

However having investigative timeliness and adjudicative timeliness for initial 

clearances at the levels called for by IRTPA does not mean we are most assuredly 

granting security clearances as quickly as desired or called for. 

• Reinvestigation timeliness has not been addressed, because the improvement 

effort focused on individuals for whom initial security clearances are required 

to perform work. 

• Not included is the time to hand-off applications to the investigative agency, 

hand-off investigation files to the adjudicative agency, return the files to the 

investigative agency for further information, if necessary, and/or generally 

complete the security clearance process within the agency, once the 

investigation and adjudication are complete. 

• Some of the performance information referenced in this report is necessarily 

for just a few months of activity; so we need to perform at the desired levels 

for longer periods of time for the information to be considered representative 

of what Industry and Agency employees can expect. 
2

Background 

Presently, the Federal government processes approximately 1.9 million requests for 

background investigations each year to support determinations of an individual’s 

suitability for employment or eligibility for access to classified information, or fulfill 

agencies’ other regulatory requirements. The average time to conduct the 

investigation had been about one year for Top Secret clearances and 5 to 6 months for 

Secret/Confidential, a totally unacceptable length of time. 

FY 04 FY 05 

Top Secret

Initial Clearance Average Days 392 days 347 days 

Investigations 

Completed 

Secret/Confidential

Average Days 179 days 155 days 

Reinvestigations 

for Top Secret 

Completed 

Average Days 579 days 482 days 

To increase attention to and accountability for the timeliness and continued quality of 

the investigations and adjudications required to grant these clearances, IRTPA 

included the following language: 

During the period beginning on a date not later than... [December 2006], each 

authorized adjudicative agency shall make a determination on at least 80 

percent of all applications for a personnel security clearance pursuant to this 

section within an average of 120 days after the date of receipt of the 

application for a security clearance by an authorized investigative agency. 

Such 120-average period shall include- 

(i) a period of not longer than 90 days to complete the investigative phase 

of the clearance review; and 

(ii) a period of not longer than 30 days to complete the adjudicative phase 

of the clearance review. 

As called for by IRTPA, the President designated OMB to lead a task force of the 

major clearance granting agencies, including the intelligence community and the 

investigations service providers, to identify areas of responsibility, establish 

performance requirements, and help hold agencies accountable for doing what they 

said they would do to improve the security clearance process. This oversight group’s 

plan to reform the process, submitted to Congress on November 9, 2005, was to: 
3

• Increase agencies’ commitment to and accountability for their part of the 

security clearance granting process, with clearer goals for each part of the 

process and regular, transparent performance information relative to those 

goals; 

• Expand investigative capacity at OPM where 90% of the investigations are 

conducted and rely initially on currently approved investigation 

methodologies; 

• Have OPM help the record repositories (FBI, DOD, DOS, etc.) identify and 

resolve impediments to timeliness, apply additional resources to the reduction 

of the backlog of old file requests, and establish work plans to achieve and 

maintain acceptable timeliness; 

• Expand adjudicative capacity as appropriate at every adjudicating agency and 

rely initially on currently approved adjudication methodologies; 

• Adopt and utilize currently available electronic file transfer capabilities to 

lessen the time to initiate an investigation and an adjudication; 

• Focus first on initial investigations versus reinvestigations; 

• Establish the reciprocal acceptance of security clearances granted by other 

agencies, called for by EO 12968 and National Security Directive 63, which 

agencies have never been held accountable for implementing; 

• Focus initially on work done by OPM and its client agencies; and 

• Organize a research and development effort to identify investigation and 

adjudication methodologies for the future and employ new techniques if 

research shows they improve the quality and/or timeliness of the security 

clearance granting process. 

All agencies have made improving the security clearance granting process a priority. 

Industry counsel on the reform efforts has been solicited monthly, and industry and 

Congress have been kept up-to-date on agency progress. 

Performance 

IRTPA calls for the average number of processing days for 80% of security clearance 

requests submitted at the end of 2006 to be 90 days or less for the investigation and 

30 days or less for the adjudication. 

Looking at initial investigations and adjudications initiated after October 1, 2006, for 

the clearance requests with the investigations performed by OPM: 

• As of February 3, 2007, 64% of the 49,633 initial clearance investigations 

initiated by OPM during October 2006 have been completed. Average 

processing time for these is 63 days, and at the current rate of processing, we 

project 80% will be completed in an average of 90 days or less. Forty-four 

percent of the 6,366 requests for Top Secret level investigations have been 
4

completed in an average of 75 days, and 67% of the 43,267 investigations for 

Secret/Confidential level have closed in an average of 61 days. 

• For 37,412 initial clearance investigations that were completed and forwarded 

to agencies for adjudication in October 2006, 71% have been reported as 

adjudicated in an average of 23 days. We project 80% will be completed in an 

average of 30 days or less.

• DOD (92% of total adjudications) has reported adjudications on 72% of their 

investigations completed in an average of 23 days. Non-DOD agencies have 

reported adjudication on 60% of their investigations completed in an average 

of 22 days. 

Looking at ALL initial investigations and adjudications completed after October 1, 

2006 (regardless of the date of submission), for the clearance requests with the 

investigations done by OPM: 

• 80% of the 154,716 initial investigations completed by OPM during the 1st

quarter of FY 07 averaged 101 days in process. The difference between the 

timeliness of these investigations versus those requested and completed after 

October 1, 2006 (63 days; see above) reflects the large number of aged 

investigations that were completed during this period, with the help of the 

additional resources being applied to the process and the more timely retrieval 

of required documents and files. 

• ALL investigations completed by OPM in FY 07 for initial clearances 

averaged 166 days. The average initial security clearance investigation took 

205 days in 2004, 188 days in 2005, and 176 in 2006. 

• Overall, OPM is making significant progress reducing the backlog of aged 

investigations. In February 2006, OPM’s pending case inventory included 

over 62,000 investigations (of all types, including reinvestigations) that were 

over one year old. As of February 3, 2007, that number was reduced to 48,163 

investigations pending in process more than one year. Of these, OPM has 

completed all required basic coverage for over 27,000 that are now awaiting 

third-party records and/or a special subject interview to address issues 

developed during the investigation. 

• For 117,054 initial adjudications completed and recorded during the first 

quarter of FY 07, 80% averaged 17 days to process, while the average time for 

all was 39 days. 

• DOD (93% of this activity) averaged 18 days for 80% of the 108,903 actions 

reported, and Non-DOD agencies averaged 15 days for 80% of the 8,151 

actions they reported. 

While reinvestigations were not the focus of the reform effort in FY 06, OPM will 

focus on achieving mutually acceptable timeliness standards for this critical workload 

in FY 07 and beyond. 
5

• 80% of all completed reinvestigations in the first quarter of FY 07 averaged 

279 days in process. As discussed later, reinvestigation timeliness will be a 

focus of the reform effort in 2007. 

The reform effort focused on investigation and adjudication timeliness for the 

clearance determinations for which OPM conducts the investigations. As part of our 

Security Clearance Oversight Team, however, the Intelligence Community and those 

agencies with a delegation to conduct their own investigations (e.g., Justice, DHS, 

and DOS) have also been working toward meeting the IRTPA standards. 

• For the Intelligence Community, 83% of all investigations and adjudications 

completed in FY 06 and the 1st quarter of FY 07 were completed in an 

average of 103 days (investigation and adjudication time combined). 

• The State Department completed 83% of 4,143 investigations initiated in the 

4th quarter of FY 06 in an average of 47 days and adjudicated 100% of its 

completed investigations in an average of 4 days. 

• The Department of Homeland Security (DHS) is developing data reporting 

mechanisms to track clearance determinations with the same level of data 

detail provided by OPM. For those investigations and adjudications for 

headquarters and the Immigration and Customs Enforcement agency (ICE), 

DHS reports that as of January 30, 2007, 72% of the 245 investigations 

initiated in October 2006 are complete with 36% of their adjudications 

completed within 30 days. 

• The Department of Justice/FBI completed 39% of 2,230 initial investigations 

completed in the 1st quarter of FY 07 within 90 days, with an overall average 

of 146 days in process. Eighty-nine percent of its adjudication actions were 

completed within 30 days, with an average processing time of 11 days. In 

general, FBI continues to address its pending inventory on a first-in, first-out 

basis. 

It should be noted that not all Intelligence Community elements have delegated 

investigative authority; those that do not utilize OPM for their investigations. 

Status of Initiatives Supporting Improved Performance

OPM

A critical factor in meeting the goals of the IRTPA was increasing the investigative 

capacity through the addition of new staff (Federal and contractor) at OPM. In the 

November 2005 plan, OPM estimated that 8,000 full time staff, working at a normal 

performance level, were required to handle annual workload projections. Additional 

resources were needed to eliminate the backlog and offset newer staff working at a 
6

less than full performance level. OPM has steadily increased staffing levels and both 

the Federal and contractor staffs are performing as planned: 

 

 March 2005: 7,819 total Staff (5,868 field staff) 

 March 2006: 8,590 total Staff (6,505 field staff) 

 January 2007: 9,367 total Staff (7,312 field staff) 

During this period of extreme growth, OPM has developed additional internal quality 

control processes to ensure that the quality of completed investigations continues to 

meet the national investigative standards. Overall, less than 1% of all completed 

investigations are returned to OPM from the adjudicating agencies for quality 

deficiencies. 

Availability of Federal Records: FBI 

In June 2006, the FBI and OPM entered into a Memo of Agreement (MOA) to reduce 

the number of OPM name check requests pending in excess of 30 days to a level that 

is in compliance with guidance promulgated by OPM pursuant to the IRTPA. 

• To add to the existing FBI name check staff, OPM provided 32 staff and the 

FBI devoted an additional 30 staff to this effort. The project started with 

69,450 security related OPM name check requests pending for over 30 days. 

Of those original name check requests, 85% have been completed as of 

February 2, 2007. Currently, 45,192 OPM name check requests remain 

pending for greater than 30 days. In FY 06, OPM submitted 1,293,754 name 

checks to the FBI. 

• The FBI and OPM are working together to automate the exchange of 

information to reduce processing time. 

• Additional FBI/OPM process enhancements and technology improvements are 

also underway. As fee adjustments are finalized to ensure adequate funding, 

and the FBI continues to automate its processes, the backlog will be 

eliminated. 

Availability of Federal Records: Other 

Checks of State Passport records are now conducted electronically, reducing the 

turnaround time from 90-110 days to 17 days on average. 

Searches of military service records are being made available electronically. Air 

Force and Army records became available in 2005, while the Navy records will be 

available in early 2007. 

Law enforcement checks are now electronically available for Alabama, Virginia, 

Maryland, South Carolina, Texas, New York and New Hampshire. As OPM 
7

conducts in excess of three million law searches each year, it is critical that it have 

electronic access to the law enforcement records when available in other states. 

Overseas Investigations

OPM sent 177 agents abroad in 2006 and closed more than 15,000 international 

leads. It has made arrangements with DOS to train and use DOS eligible family 

members as independent investigative contractors, and has created the International 

Investigations Unit to better manage and track the workload. 

Reciprocity 

Mutually agreed upon standards for reciprocal recognition of security clearances 

were issued by the Administration in December 2005. Additional standards were 

issued in July 2006 to address unique challenges represented by special access 

programs due to their extra sensitivity. Copies of both memoranda are included in 

the appendix. In addition, the following steps have been taken to help ensure 

clearance reciprocity: 

• An interagency collaboration forum was established to increase familiarity 

with processes, procedures, and issues as well as to build confidence in each 

other’s clearance adjudicative decisions; 

• Personnel Security Reciprocity Reviews were conducted at all agencies with a 

sizable number of cleared personnel in order to identify inconsistencies in 

application of policy and to provide a mechanism for resolution; 

• A uniform program of instruction for agency adjudicative personnel was 

developed and promulgated, including core content and learning objectives, in 

order to further consistent clearance decisions from agency to agency; and 

• A monthly sampling process was established in collaboration with a number 

of industry associations that represent companies that perform on classified 

contracts with the government, in order to assess progress in meeting 

reciprocity standards. 

Based upon feedback from industry and other sources, we recognize that many 

perceived failures in clearance reciprocity actually stem from the varied standards 

employed by agencies to determine suitability for employment or suitability for 

access to unclassified spaces and information systems. We have initiated efforts to 

reconcile suitability and clearance eligibility standards to the extent practicable. 

Use of eQIP 

Electronically submitting the information required for a security clearance 

investigation reduces the overall time to get a clearance two to three weeks at a 
8

minimum. Although the eQIP electronic application has existed since 2003, agencies 

were only held accountable for using it starting in January 2006. Overall use of the 

form has increased dramatically, and DOT and DOC and several small agencies are 

currently meeting the goal of 100% eQIP usage. 

Percent of Investigations 

Submitted Using eQIP

1st Qtr, 

FY06 

1st Qtr, 

FY07 

January 

2007 

All Agencies 34% 65% 64% 

DOC 7% 100% 100% 

DOD 36% 65% 69% 

DOE 0% 68% 79% 

DHS 6% 64% 63% 

DOJ 0% 60% 94% 

DOT 74% 100% 100% 

All agencies that use eQIP plan to achieve 100% eQIP usage in FY 07. 

R&D 

In support of the Security Clearance Oversight Committee, the Office of the Director 

of National Intelligence has organized an R&D subcommittee, with membership from 

across the Executive Branch. The subcommittee’s goal is to establish and execute a 

national personnel security research agenda to identify the new standards and 

methodologies that will be necessary for timeliness to be reduced to 40 days for 

investigation and 20 days for adjudication. The priority areas for research are: 

 

• Electronic transmission of all related records 

• Revalidation of all investigative standards and adjudication guidelines 

• Utility of internet and/or other commercially available data sources 

• Opportunities to increase the integrity of the applicant interview 

• Opportunities to better assess an applicant’s allegiance 

• Opportunities to prescreen prospective applicants 

• Opportunities to get more candid information from an applicant’s supervisor 

• An automated tool to assist with adjudicative decisions 

Timetables will be agreed to in the next month and research will begin thereafter. The 

agenda will include short and long-term projects that involve both public and private 

sector resources, including: internal ODNI resources, the Department of Defense’s 

Personnel Security Research Center (PERSEREC), as well as academic and 

commercial entities with relevant expertise. 
9

Automated Continuing Evaluation 

PERSEREC is conducting a pilot test for DHS of the Automated Continuing 

Evaluation System (ACES) that it developed for DOD. DHS plans to employ ACES 

between periodic reinvestigations and as a risk management tool during individuals’ 

employment. This tool, combined with the Phased Periodic Reinvestigation for Top 

Secret clearances, has the potential for providing critical information between 

reinvestigation cycles while reducing the labor intensive field coverage required in a 

full-scope reinvestigation.

Industry Feedback 

Clearance processing times are especially critical to companies that perform on 

classified contracts with the government and most companies track them. As recently 

as September 2006, representatives of industry reported that access eligibility 

determinations based upon an initial Single Scope Background Investigations (SSBI) 

for their employees reflected an average end-to-end completion in excess of a year. 

A working group comprised of representatives of both government and industry 

recently conducted an end-to-end audit of a limited sample of initial SSBI industry 

cases that were posted as adjudicated in September 2006. This audit confirmed that 

the average end-to-end processing time for these cases was consistent with industry’s 

reported experience. 

Since approximately two-thirds of the cases were part of a longstanding backlog and 

the investigations were initiated before 2006, the lengthy investigative times were not 

entirely unexpected. As the backlog declines, overall end-to-end processing times 

will continue to improve. The adjudicative times for the audited cases, being more 

recent, were within the current 30-day goal. 

Nonetheless, the audit revealed the need for continued process improvements and the 

creation of a case life-cycle tracking system, at least for industry, to encompass endto-end metrics so as to better reflect actual experience. Specific areas requiring 

continued attention include: 

• The time between when an industry employee is authorized to begin 

completion of the personnel security questionnaire (PSQ) and it is accepted by 

Defense Industrial Security Clearance Office (DISCO), a component of the 

Defense Security Service that serves as the central clearance authority for 

industry. 

• The time it takes for the PSQ to be processed and forwarded by DISCO and 

scheduled for investigation by OPM. 

• The time it takes for the investigative results to be forwarded by OPM and 

received by DISCO. 
10

• The additional elapsed time when a completed investigation does not result in a 

clearance eligibility determination for various reasons, to include the need for 

additional investigative activity, loss of jurisdiction, transfer of adjudicative 

responsibility to another Central Adjudication Facility (CAF) or due process 

considerations. 

• The additional time it takes when a completed case is forwarded to another 

CAF for adjudication of Sensitive Compartmented Information access. 

As a result of this study, OPM and DOD will develop and institutionalize a 

comprehensive system of metrics, to include key data points such as those described 

above, to measure timeliness of the end-to-end clearance process for industry. 

Priority Challenges/Opportunities to Be Addressed

Non-legislative 

OPM investigation timeliness is impacted by the fact that record repositories, 

especially FBI, must continue to apply additional resources to get and stay current 

(i.e., provide 90% of the requested files within 30 days). 

Legislative and Legal 

OPM investigation timeliness is impacted by the fact that: 

• Many state and local agencies (such as California Department of Justice) 

restrict access to their records, charge OPM unreasonable fees, or fail to 

respond to requests in a timely manner; 

• OPM-FISD is not recognized as a criminal justice agency. Therefore it is often 

denied access to Criminal History Record Information (CHRI) that would 

normally be released to other agencies with criminal justice components (i.e., 

the FBI, CIA, DOD, etc.);

• In some jurisdictions, Federal contractors are not considered under the term 

“covered agency” for the purpose of conducting federal investigations, thus 

making agencies reluctant to release CHRI to OPM contractors. Contractors 

have been denied access to CHRI because they are considered as “businesses 

for profit” and are charged fees as if they are representing private investigative 

agencies; 

• OPM-FISD lacks the full authority and protections to operate internationally 

when conducting Federal background investigations; 

• Private employers are reluctant to cooperate with OPM investigators without a 

“hold harmless” clause to shield employers and their employees from 

providing information to OPM. 
11

Goals for December 2007, in light of December 2009 goals

As stated above, new investigation methodologies must be identified to achieve the 

2009 IRTPA goals, especially the 40-day timeliness goal for investigations. As the 

likely impact of potential new methodologies will not be known until the end of 2007 

and/or beyond, it is premature to establish performance goals for 2008, and determine 

if the December 2009 goals are achievable and in the best interest of national 

security. 

In general in 2007, we think our appropriately aggressive goals should be to: 

• Clearly and consistently perform at slightly better than the 12/06 IRTPA goal 

level, 

• Ensure we are reforming the entire security clearance granting process, beyond 

just the time it takes to conduct the investigations and adjudications. 

More specifically we will hold ourselves accountable for accomplishing the 

following for 12/07: 

• 85% of initial clearance investigations completed within an average of 90 days; 

• Priority processing (less than 40 days on average) will be available for up to 

10% of initial investigations; 

• 80% of reinvestigations completed within an average of 180 days; 

• Priority processing (less than 40 days on average) will be available for up to 

10% of reinvestigations; and 

• 80% of adjudications completed within an average of 25 days. 

And supporting these performance targets: 

• Participating agencies will achieve 100% eQIP usage, with submission of all 

required data and forms for investigation within 14 days or less from the date 

the subject provides all required material. Less than 5% of all submissions 

will be rejected due to errors in submission. 

• With the help of OPM, the record repositories will achieve the goal of 

producing 90% of the requested files/information in 30 days or less. 

• OPM will develop the capacity to electronically transmit completed 

investigations and agencies will develop parallel systems to receive completed 

investigations electronically, eliminating mail and handling time. 

• Agencies will measure and report additional adjudicative time required to 

process clearances when access to SCI or SAP information is involved. 

• OPM and DOD will measure timeliness of the end-to-end clearance process for 

industry and develop and implement necessary process improvements. 

• Agencies and OPM will develop additional measures of investigation quality, 

if possible. 
12

Appendix 

1. Security Clearance Investigation Processing – Agency Performance Report 

2. December 12, 2005 Memorandum on Reciprocal Recognition of Existing 

Personnel Security Clearances 

3. July 17, 2006 Memorandum on Reciprocal Recognition of Existing Personnel 

Security Clearances 

4. Title III of the Intelligence Reform and Terrorism Prevention Act of 2004 

(Public Law No: 108-458) 
13
EXECUTIVE OFFICE OF THE PRESIDENT 

OFFICE OF MANAGEMENT AND BUDGET 

WASHINGTON, D.C. 20503 

DEPUTY DIRECTOR 

FOR MANAGEMENT 

December 12, 2005 

Memorandum for Deputies of Executive Departments and Agencies 

From: Clay Johnson III 

 Deputy Director for Management 

Subject: Reciprocal Recognition of Existing Personnel Security 

Clearances 

The Federal government is committed to significantly improving the process by 

which we determine eligibility for access to Classified National Security Information. 

This commitment is reinforced by requirements to improve the security clearance 

process included in Title III or Public Law 108-458 (The Intelligence Reform and 

Terrorism Prevention Act of 2004) and Executive Order 13381 (Strengthening 

Processes Relating to Determining Eligibility for Access to Classified National 

Security Information). A significant part of this reform is ensuring that background 

investigations are conducted to grant new security clearances only when they are 

actually required. 

The attached paper outlines the various issues currently inhibiting reciprocity of 

security clearances, and the actions you and others are required to take to address 

them. Your department or agency, and all others, are responsible for the actions 

highlighted in bold. 

This reciprocity guidance was developed by a Security Clearance Oversight Steering 

Committee, which includes representatives from DoD, DHS, DOE, DOJ, DOT, DOC, 

DOS, the DNI, the NSC, and the National Archives and Records Administration. I 

am the Chairman. 

If you have any questions about the requirements contained in this document, please 

contact me at (202) 456-7070. 

cc: Departments and Agencies Directors of Security 

14
15

Enforcing Reciprocity of Existing Personnel Security Clearances

1. Issue: There is an inconsistent understanding among the agencies with respect to when 

reciprocal recognition of an existing clearance is required. 

(a) Required Action: The attached checklist is designed to assist agencies in determining 

when reciprocal recognition of existing clearances is required and should be used 

whenever applicants indicate that they posses an existing access eligibility 

determination at the same or higher level than currently needed.

2. Issue: The existing central database does not provide sufficient clearance verification 

information on a real-time basis to enable agencies to ascertain the status of an individual’s 

security clearance. 

(a) Required Action: OPM has added additional data fields to the Clearance Verification 

System (CVS) so as to differentiate between those access eligibility determinations that 

require reciprocal recognition and those that do not (see attachment 2 for required data fields 

and explanation). These additional fields will be fully incorporated in CVS by December 17, 

2005. 

(b) Required Action: While agencies are migrating to CVS, OPM will develop and 

promulgate guidance that directs agencies to: i) query DoD’s JPAS database if the existing 

clearance was issued by a DoD activity; ii) query the Intelligence Community’s Scattered 

Castles database if the existing clearance was issued by an intelligence community agency; 

or iii) query the appropriate agency via phone or fax using a comprehensive master list of 

agency points of contacts to be developed and promulgated by OPM (see attachment 3 for 

prescribed “Inter-Agency Clearance Verification Request” and attachment 4 for a draft 

“Master List of Agency Contacts”). A listing of agency points of contact is posted along 

with prescribed verification format to OPM’s web portal site, https://opmis.xsp.org. 

(c) Required Action: Agencies will begin daily updates to OPM’s Clearance Verification 

System (CVS) and to update existing entries by March 31, 2006. This date is dependent 

upon the ability of affected agencies to develop and implement the necessary technical 

interfaces that will permit daily updates. An OPM directed working group is currently 

examining what barriers exist to all agencies using this system and will resolve those issues 

as they arise. 

3. Issue: A permitted exception to reciprocity may occur when an individual is being considered 

for access to a program of a sensitivity level different from that of the existing program. This 

step only applies to SCI, SAP and Q programs and only when the new program has 

investigative and/or adjudicative criteria at the time the program is approved by the agency head 

or deputy that are higher than standards set forth in Executive Order 12968 (applies to State, 

Energy, Defense, DHS, CIA and DNI only – the only agencies authorized to establish SAPs). 

Reciprocity has proved most elusive when individuals (especially cleared contractors) cross 

over to different programs that entail access to TOP SECRET, SAP and/or SCI information. 

This is due, in part, to the significant discretion agency heads had been granted by Executive 

Order 12968 to establish “additional but not duplicative investigative or adjudicative criteria” 

for SAPs, to include SCI. While no standards exist regarding acceptable higher investigative or 

adjudicative criteria and the circumstances under which they are appropriate – the two most 

common are: i) a requirement for a polygraph examination, and ii) outright disqualification 
16

based upon non-U.S. immediate family members (although the latter is the most frequently 

waived disqualifier). 

(a) Required Action: OPM is configuring CVS to reflect on a real-time basis those individuals 

who have undergone a polygraph (as the Intelligence Community’s Scattered Castles 

database currently does) and agencies must begin inputting required data for all new and 

existing clearances on December 17, 2005. 

(b) Required Action: For those agencies without access to Scattered Castles, or to verify 

polygraphs at agencies that don’t post to Scattered Castles, OPM will provide in the 

aforementioned clearance verification request and master list of agency points of contact the 

means to manually verify via phone or fax whether an individual has undergone a polygraph 

examination. This information can be found on OPM’s web portal (https://opmis.xsp.org). 

(c) Required Action: Agencies will update by March 31st, 2006 their records in OPM’s 

Clearance Verification System to reflect those cleared individuals who have undergone 

a polygraph and/or, to the extent practical, have non-U.S. immediate family members. 

(While reflecting non-U.S. immediate family members for new clearances should not prove 

difficult, it may be problematic for those agencies without the authority to grant SCI or SAP 

access to annotate existing records). 

(d) Required Action: While Executive Order 12968 allows agency heads to establish 

additional but not duplicative investigative or adjudicative requirements for SAPs, to 

include SCI, agencies will, in accordance with Executive Order 13381: 

• Limit such additional requirements to the polygraph examination and/or 

disqualifying individuals based upon non-U.S. immediate family; and 

• Ensure that programs desiring to utilize or continue to use additional 

requirements other than the above for the purpose of determining eligibility for 

access to classified information first obtain the approval of the Director of OMB in 

accordance with §3001(d)(3)(A), Title III, Public Law 108-548 by January 31, 2006 

and as new programs are established thereafter. 

(e) Required Action: The Personnel Security Working Group of the Records Access and 

Information Security PCC will evaluate the need to formalize changes to existing policy 

documents that codifies the above by January 31, 2006. 

4. Issue: Oftentimes, it is difficult to distinguish between employment suitability issues and 

security clearance trustworthy issues. Unique suitability issues serve as impediments to 

reciprocity. For example, a military veteran or a contractor employee with a current, final 

Secret clearance is not eligible for immediate Federal employment since the suitability 

investigation for Federal employment differs from the investigation for a Secret clearance. 

(a) Required Action: The Personnel Security Working Group of the Records Access and 

Information Security PCC will evaluate by February 28, 2006 the need for policy changes 

that ensure consistency between the basic investigative requirement to determine suitability 

for Federal employment and the basic investigative requirement for access to information 

classified Secret and below. 
17

(b) Required Action: As this is being developed, agencies must be cognizant that unique 

suitability issues such as requirements for psychological or medical evaluations as well as 

the unwillingness to accept certain mitigated issues (e.g. past drug usage of any vintage 

serving as a bar to employment as a DEA agent) will always contribute to the perception 

that reciprocity is not being honored. Agencies must ensure that in such instances, the 

completion of an entirely new security questionnaire or the conduct of duplicative 

investigative checks does not occur. Rather, only additional, not duplicative, 

investigative and adjudicative procedures will be completed.

5. Issue: Lack of reciprocity often arises when there is reluctance to be accountable for poor 

quality investigations and/or adjudications conducted by prior agencies or organizations. While 

reciprocity has proved elusive by fiat and in the absence of any accountability for performance, 

confidence among security practitioners in the quality of each other’s work can be increased. 

(a) Required Action: Working with the Department of Defense, the Intelligence Community 

has developed standardized training for all adjudicators. This week-long course enhances 

the level of competence and understanding of adjudication fundamentals to include the 

principles of reciprocity by systematically presenting the Adjudicative Guidelines, providing 

practical hands-on case studies, and exposing students to a coherent way of thinking about 

adjudication. In this vein, the Reciprocity Working Group will identify by February 15, 

2006 additional opportunities to provide such content to adjudicators Executive branch-wide 

through uniform, high quality training, along with opportunities for better communication 

with all security managers and adjudicators to ensure familiarity with and understanding of 

the “new way of doing business.” 

(b) Required Action: An important way to foster mutual confidence is to provide mechanisms 

where personnel security practitioners can collaborate on issues of common interest. The 

intelligence community is convening a forum for such collaboration under the name 

“Common Adjudicative Procedures for the SCI Community” or CAPSC. This forum shall 

be expanded Executive branch-wide to include the non-SCI community and be assigned 

specific responsibilities to report to OMB. 

6. Issue: Metrics are essential in order to measure progress. 

(a) Required Action: The aforementioned CAP Forum, with respect to any agency’s 

adjudicative activity relating to the issuing of security clearances to include posting data to 

CVS, is assigned responsibility to: consider and make recommendations to OMB on 

complaints and suggestions; organize and oversee periodic on-site peer reviews; and provide 

quarterly progress reports to OMB.

(b) Required Action: For industry, through the “MOU Associations,” contractors shall report 

quarterly, on a voluntary basis, the total number of times their employees have completed a 

security questionnaire and of those, the number of times it appeared to the contractor to be 

in contravention of the “Checklist of Acceptable Exceptions to Reciprocity.” These trend 

reports would be submitted through the Information Security Oversight Office. 

(c) Required Action: Additional metrics for measuring agencies’ progress toward meeting the 

reciprocity standards will be developed within 60 days and provided to you. 

(d) Required Action: Agencies will be expected to report to OMB by April 1, 2006, the 

status of their implementation of the new procedures relative to the reciprocity of 
18

access eligibility determinations, to include the updating of agency regulations, as 

appropriate. OMB will provide you with a format for that report.

(e) Required Action: OMB will issue a report by May 1, 2006 which provides feedback to 

agencies on the progress made Executive branch-wide with respect to the reciprocity of 

access eligibility determinations. 
19

Milestones 

Task Responsible 

Party 

Due Date 

1. Master List of Agency Contacts posted to OPM 

web portal 

OPM Complete 

2. Procedures for verifying existing access eligibility 

determinations posted to OPM web portal 

OPM 12/15/05 

3. Procedures for joining collaboration forum for 

adjudicators posted to OPM web portal 

OPM 12/15/05 

4. Finalize format for industry trend reports NARA Complete 

5. Initial organizing meeting of collaboration forum DNI 12/15/05 

6. Additional data fields essential for reciprocity 

available in CVS 

OPM 12/17/05 

7. Deadline for agencies wanting to continue criteria 

over and above polygraph and non-U.S. immediate 

family member disqualifier for existing programs 

to request specific approval from OMB 

Agencies 1/31/06 

8. Reciprocity Working Group to identify additional 

opportunities to present uniform, high quality 

training and to enhance communication 

NARA 2/15/06 

9. Reciprocity WG to identify additional metrics for 

measuring agencies progress toward meeting the 

reciprocity standards 

NARA 2/15/06 

10. PCC evaluation of need for additional policy 

changes 

PCC 2/28/06 

11. Initial peer review of agency adjudicative 

responsibilities 

NARA 3/1/06 

12. Initial agency implementation reports submitted to 

OMB 

Agencies 4/1/06 

13. Initial forum report to OMB DNI 4/1/06 

14. Initial trend report from industry groups NARA 4/1/06 

15. Initial OMB report on the state of reciprocity OMB 5/1/06 

16. CVS IOC which allows agencies to update entries 

daily 

OPM TBD 

17. CVS FOC which requires agencies to update daily 

those data fields essential for reciprocity for 

existing and new entries 

OPM TBD 
Checklist of Permitted Exceptions to Reciprocity 

(to be used whenever you make an eligibility determination for access to classified 

information for an individual who has a current access eligibility based upon the requisite 

investigation (i.e. ANACI, NACLC, SSBI, or SSBI-PR) 

For the purpose of determining eligibility for access to classified information, to include highly 

sensitive programs (i.e. SCI, SAPs and Q), as the gaining activity/program for an individual who 

has current access eligibility with another Federal agency or program: 

• you cannot request the individual to complete a new security questionnaire; 

• you cannot review existing background investigations for the individual; 

• you cannot review existing security questionnaires for the individual; 

• you cannot initiate any new investigative checks; 

unless one or more of the questions below can be answered in the affirmative. 

Yes No N/A 

1. Is the existing clearance granted on an interim or temporary basis? 

2. Is the investigation upon which the existing clearance is based more 

than seven years old for TOP SECRET, ten years old for SECRET 

and fifteen years old for CONFIDENTIAL? 

3. Is your activity (i.e. the gaining activity) aware (i.e. already in 

possession) of substantial information indicating that the standards 

of E.O. 12968 may not be satisfied? 

If the individual is being considered for access to a highly sensitive program (i.e. SCI, SAP or Q) at 

your activity:

4. Is the existing access eligibility determination based upon a waiver 

or deviation, or is access otherwise subject to conditions? 

5. If applicable, does the individual not satisfy a polygraph 

requirement imposed by the new program, as approved by the 

agency head or deputy?∗

6. If applicable, does the individual not satisfy a requirement imposed 

by the new program that does not allow any non-U.S. immediate 

family, as approved by the agency head or deputy? ∗

7. If applicable and if approved by OMB, other than for questions 5 

and 6 above, does the individual not satisfy an investigative and/or 

adjudicative criterion that is additional to the standards set forth in 

E.O. 12968? ∗

Items 1 and 2 and 4 through 6 above can be verified by querying OPM’s Clearance Verification 

System (CVS), the Department of Defense’s Joint Personnel Adjudication System (JPAS), or the 

Intelligence Community’s Scattered Castles database. If you do not have on-line access to the 

appropriate database, or if the record is otherwise incomplete, you can fax an “Inter-Agency 

Clearance Verification Request” to the appropriate agency. The request form and appropriate fax 

numbers can be found at: https://opmis.xsp.org

_________________ 

∗ Under such circumstances, the completion of an entirely new security questionnaire is not authorized. Rather, only 

additional – not duplicative – investigative or adjudicative procedures will be completed. 

20

Attachment 1 
CVS Reciprocity Data Elements 

 The following 19 items are the data elements required to be in the Clearance Verification 

System in order to support reciprocity. The remarks, keyed to the line numbers, explain what each 

element includes and, where necessary, detailed information about how to formulate it. 

Identity 

1. Name, last 

2. Name, first 

3. Name, middle 

4. Name, suffix 

5. SSN 

6. DOB 

Investigation 

7. Investigation type 

8. Investigation date 

9. Polygraph type 

10. Polygraph agency 

11. Polygraph date 

Clearance 

12. Clearance Level 

13. Special Access 

14. Date of Eligibility 

15. Interim clearance 

16. Status 

17. Adjudicative authority 

Alerts 

18. Non-US Immediate Family 

19. PLEASE CALL 

REMARKS

 Entries are in ALL CAPS. 

1. Last name. Convention: Reflect spacing in multi-word names (e.g., DE SILVA, not 

DESILVA), hyphens in hyphenated names (e.g., SCHMITT-WALTER, not SCHMITT WALTER 

or SCHMITTWALTER), and apostrophes in names with them (e.g., O’NEILL, not ONEILL). 

Ignore non-standard characters (e.g., GLUCK, not GLÜCK; GUINOT, not GUINÔT; NGO DINH, 

not NGÔ ĐÌNH). Treat ligatures as separate letters (e.g., FAERNISE, not FÆRNISE); reflect 

German ß as SS. 

2. First name. Convention: as above. Use “(IO)” to indicate initial only [e.g., E. (IO)]. 

Include periods with initials. 

3. Middle name. Convention: as above. Use “(IO)” to indicate initial only [e.g., E. (IO)]; use 

“(NMN)” to indicate no middle name. Include periods with initials. If a person has more than one 

21 Attachment 2 
22

middle name, include only the first (e.g., reflect John Robert Thomas Duran’s middle name as 

ROBERT, not ROBERT THOMAS). 

4. Suffix. JR., SR., II, III, IV, etc. Do not include honorifics (e.g., ESQ.), degrees (e.g., 

M.D.) or anything else not integral to the person’s name. If none, leave blank. 

5. SSN. Use nine consecutive digits, without spaces or hyphens (e.g., 000000000, not 000-

00-0000 or 000 00 0000). 

6. DOB. Use the DD-MMM-YYYY convention: thus reflect July 4, 1976 as 04-JUL-1976. 

7. Investigation type. List the most recently completed personnel security investigation, 

using standard designators, e.g., SSBI, SSBI-PR, NACLC, ANACI, NACI, MBI. 

8. Investigation date. Use the closing date appearing on the investigation, not the initiation 

date or date of adjudication. Use the DD-MMM-YYYY convention. 

9. Polygraph type. This and the following two fields relate only to polygraphs administered 

as a part of security processing. Record only the most recent polygraph. Reflect the type as either 

CI (counterintelligence scope) or FS (full scope). If there is no polygraph, enter NONE. 

10. Polygraph agency. Use the standard designator for the agency administering the polygraph 

(e.g., CIA, NRO, NSA). Use USAF for Air Force, USN for Navy, and USA for Army. 

11. Polygraph date. Use the date of the examination as reflected in agency records. 

12. Clearance level. Reflect the highest level of clearance: Use CONF for Confidential, SEC 

for Secret, and TS for Top Secret. Use NONE if no clearance determination has been made or if the 

person has been determined ineligible (denied or revoked). For DOE access authorizations, use L 

or Q. 

13. Special Access. Reflect whether the person has been determined eligible for either 

Sensitive Compartmented Information, other Special Access Programs, or both. Use SCI, SAP, and 

SAPSCI. If no special access eligibility has been determined, enter NONE. 

 Note: Items 12 and 13, when taken together, indicate the type of adjudication the person has 

undergone. Some examples: 

Clnc 

Level 

Sp Acc Meaning 

TS NONE Favorable adjudication for TS, no SCI or SAP 

determination 

TS SCI Favorable adjudication for Top Secret with eligibility 

for SCI 

SEC NONE Favorable adjudication for Secret, no SAP 

determination 

SEC SAP Favorable adjudication for Secret and for SAPs at the 

Secret (but not Top Secret) level 

TS SAPSCI Favorable adjudication for Top Secret with eligibility 

for both Top Secret SAPs and SCI 

14. Date of eligibility. Date of the most recent favorable adjudication. Use the DD-MMMYYYY convention. 

15. Interim clearance. Indicate YES if the clearance level reflected in the record is based on an 

open investigation. Otherwise enter NO. 

16. Status. Use ACTIVE (meaning the person currently occupies a position requiring some 

level of classified access), SUSP (meaning the person has been suspended from access but not 

debriefed), or DEBR (meaning the person is currently debriefed from all classified access). DEBR 

is without respect for reason. 
23

 

17. Adjudicative authority. Standard designator of the agency granting the clearance 

eligibility. 

18. Non-US immediate family. Enter YES if any of the person’s living immediate family 

members (father, mother, brother, sister, spouse, son, daughter, or cohabitant) is not a US citizen. 

Each of these terms includes all its variants; e.g., “sister” includes sister by blood, sister by 

adoption, half-sister, stepsister, and foster sister. If all immediate family members are US citizens, 

enter NONE. 

19. PLEASE CALL. Use PLEASE CALL to alert system users only if one of the following 

applies: 

♦ waivers (access eligibility granted or continued despite the presence of substantial 

issue information that would normally preclude access); 

♦ conditions (access eligibility granted or continued with the proviso that one or more 

additional measures will be required, such as additional security monitoring, 

restrictions on access, and restrictions on an individual’s handling of classified 

information); 

♦ deviations (access eligibility granted or continued despite either a significant gap in 

coverage—meaning complete lack of coverage of a period of six months or more 

within the most recent five years investigated—or a significant deficiency in the 

scope in the investigation, such as the absence of all employment checks);1

♦ suspensions of access; 

♦ revocations of access; 

♦ denials of access; and 

♦ ongoing investigations that could affect the person’s continued eligibility for access. 

1

 Do not use PLEASE CALL to flag cases with out-of-date investigations unless one of the other 

reasons in this list applies. 
24

Some Sample Records 

1. TS clearance, no SAP or SCI 

Name Last 

BRAUNBOX 

Name First 

THEODORE 

Name Middle 

MICHAEL 

Name Suffix 

JR. 

SSN 

000000000

DOB 

03-MAY-1902

Inv Type 

SSBI-PR

Inv Date 

05-JUN-2002

Poly Type 

NONE

Poly Agency Poly Date 

Clnc Level 

TS

Spec Access 

NONE

Date of Elig 

06-AUG-2002

Interim Clnc 

NO

Status 

ACTIVE

Adj Auth 

JUSTICE 

Non-US Fam 

NONE

2. Secret clearance, foreign relatives 

Name Last 

LAUFKOETTER 

Name First 

MARY 

Name Middle 

(NMN) 

Name Suffix SSN 

000000000

DOB 

06-DEC-1983

Inv Type 

NACLC

Inv Date 

30-APR-2005

Poly Type 

NONE

Poly Agency Poly Date 

Clnc Level 

SEC

Spec Access 

SAP

Date of Elig 

06-MAY-2005

Interim Clnc 

NO

Status 

ACTIVE

Adj Auth 

USAF 

Non-US Fam 

YES

3. TS clearance, SCI eligibility with a condition applied, polygraph 

Name Last 

QWINE 

Name First 

FRANK 

Name Middle 

R. (IO) 

Name Suffix SSN 

000000000

DOB 

17-FEB-1950

Inv Type 

SSBI

Inv Date 

26-MAY-2000

Poly Type 

FS

Poly Agency 

CIA 

Poly Date 

13-JUN-2001

Clnc Level 

TS

Spec Access 

SCI

Date of Elig 

10-NOV-2003

Interim Clnc 

NO

Status 

ACTIVE

Adj Auth 

CIA 

Non-US Fam 

NONE PLEASE CALL 

4. Favorably adjudicated for Secret, not currently in access 

Name Last 

ASQUE 

Name First 

SANDRA 

Name Middle 

SARAH 

Name Suffix SSN 

000000000

DOB 

09-NOV-1961

Inv Type 

ANACI

Inv Date 

05-MAR-2004

Poly Type 

NONE

Poly Agency Poly Date 

Clnc Level 

SEC

Spec Access 

NONE

Date of Elig 

11-APR-2004

Interim Clnc 

NO

Status 

DEBR

Adj Auth 

TREASURY 

Non-US Fam 

NONE
25

5. Temporary access eligibility 

Name Last 

HEAP 

Name First 

URIAH 

Name Middle 

DICKENS 

Name Suffix 

III 

SSN 

000000000

DOB 

22-AUG-1970

Inv Type 

NONE

Inv Date Poly Type 

NONE

Poly Agency Poly Date 

Clnc Level 

SEC

Spec Access 

NONE

Date of Elig 

6-AUG-2002

Interim Clnc 

YES

Status 

ACTIVE

Adj Auth 

COMMERCE 

Non-US Fam 

NONE

5. Access revoked 

Name Last 

MALAHIDE 

Name First 

MARY 

Name Middle 

BARBARA

Name Suffix SSN 

000000000

DOB 

05-MAY-1977

Inv Type 

SSBI

Inv Date 

17-MAY-2002

Poly Type 

CS

Poly Agency 

USAF 

Poly Date 

03-NOV-2004

Clnc Level 

NONE

Spec Access 

NONE

Date of Elig Interim Clnc 

NO

Status 

DEBR

Adj Auth 

USAF 

Non-US Fam 

NONE PLEASE CALL 

6. Access suspended 

Name Last 

BOSKNECHT 

Name First 

IAGO 

Name Middle 

RONALD

Name Suffix 

SR. 

SSN 

000000000

DOB 

30-JUN-1935

Inv Type 

SSBI

Inv Date 

17-MAY-2002

Poly Type 

NONE

Poly Agency Poly Date 

Clnc Level 

TS

Spec Access 

SCI

Date of Elig 

27-MAY-2002

Interim Clnc 

NO

Status 

SUSP

Adj Auth 

USAF 

Non-US Fam 

NONE PLEASE CALL 
Inter-Agency Clearance Verification Request 

The U.S. Government agency indicated below is requesting that you provide them with specific data 

pertaining to security clearance information your agency might maintain on the subject whose 

identifying information is provided hereon. This request is being made because a search of 

appropriate databases failed to disclose pertinent information. 

SUBJECT NAME: ____________________________________________________________ 

 Last First Middle Suffix 

SSN: ____________________ DOB: ____________________ 

CLEARANCE (C/S/TS): ____________ GRANT DATE: _______________ 

IS THIS CLEARANCE ACTIVE? YES_____ NO _____ 

IF NO, WAS THIS CLEARANCE: SUSPENDED _____ REVOKED _____ 

ADMINISTRATIVELY WITHDRAWN _____ DENIED ______ 

PROVIDE DATE OF ACTION FOR ANY OF THE ABOVE: ____________ 

IS THIS AN INTERIM OR TEMPORARY CLEARANCE? YES _____ NO _____ 

WHAT AGENCY ADJUDICATED THIS CLEARANCE? ________________________ 

INVESTIGATIVE BASIS: 

TYPE OF INVESTIGATION: ______________ DATE INVESTIGATION CLOSED: ___________ 

WHAT AGENCY CONDUCTED THE INVESTIGATION? _________________________________ 

(FOR ACCESS TO HIGHLY SENSITIVE PROGRAMS ONLY) 

COMPLETE THE BELOW ITEMS ONLY IF CHECKED: 

______ DOES THIS CLEARANCE CARRY ANY WAIVERS, DEVIATIONS OR CONDITIONS? 

YES ______ NO _____ 

______ WAS A POLYGRAPH EXAMINATION CONDUCTED? YES_____ NO _____ 

IF YES, INDICATE TYPE: ________ DATE: _______ AGENCY: ______________________ 

______ DOES THE SUBJECT HAVE ANY NON-U.S. FAMILY MEMBERS? 

YES ______ NO _____ 

PLEASE COMPLETE THIS FORM AND RETURN IT AS SOON AS POSSIBLE TO: 

AGENCY NAME: ________________________________________ 

CONTACT PERSON: _____________________________________ 

FAX: _________________________ PHONE: __________________ 

26

Attachment 3 
EXECUTIVE OFFICE OF THE PRESIDENT 

OFFICE OF MANAGEMENT AND BUDGET 

WASHINGTON, D.C. 20503 

DEPUTY DIRECTOR 

FOR MANAGEMENT 

July 17, 2006 

M-06-21 

 

MEMORANDUM FOR DEPUTIES OF EXECUTIVE DEPARTMENTS AND AGENCIES 

 

From: Clay Johnson III 

 Deputy Director for Management 

 

Subject: Reciprocal Recognition of Existing Personnel Security Clearances 

 

The OMB memorandum of December 12, 2005, on this same subject, outlined the various issues 

that inhibit reciprocity of security clearances and the actions required to address them. Since then, 

it has become apparent that additional actions are required to further reciprocity with respect to 

special access programs (SAPs). In that vein, paragraph 3(d) of the referenced memorandum is 

revised as follows: 

 

(d) Required Action: While Executive Order 12968 allows agency heads to 

establish additional but not duplicative investigative or adjudicative requirements 

for SAPs (including SCI) or for detail or assignment to their agencies,* agencies 

will limit such additional requirements to the following: 

• Administering polygraph examinations. 

• Disqualifying individuals based upon non-U.S. immediate 

 family members.† 

• Requiring personnel security investigations completed within 

 seven years irrespective of the classification level of the SAP. 

 The requirement to submit the Periodic Reinvestigation packet 

 NLT the 5th year anniversary remains unchanged.

In lieu of the polygraph, agencies may require personnel: 

• Seeking initial access to a SAP at each agency‡ (or access to a 

 SAP at a higher classification level than a SAP currently 

accessed) to submit a current SF 86 (defined as completed and 

signed within the last year). 

• Already accessed to a SAP to submit an updated and signed SF 

 86 or a SF 86C on an annual basis. 

The Checklist of Permitted Exceptions to Reciprocity, provided with the referenced OMB 

memorandum, is revised to reflect the above and is attached. 

 

*

 That is, special access programs in the specific sense of EO 12958, sec. 4.4. 

†

 Other than this one exception, access eligibility determinations for SAPs will be made in accordance with national 

adjudicative guidelines. 

‡

 For purposes of reciprocity, all components of the Department of Defense to include the Military Departments and 

Defense Agencies shall be considered one agency. 

27
28

 

Any agency head who determines that it is necessary to impose additional requirements, other than 

the above, for the purpose of determining eligibility for access to classified information will notify 

the Director of OMB. 

 

Agencies will make SAP access eligibility determinations with the goal of making 80% of all 

determinations within 30 days. 

 

The Records Access and Information Security PCC will initiate action to formalize the above 

change in existing policy documents. 

 

 

Attachment 
Checklist of Permitted Exceptions to Reciprocity

(to be used whenever you make an eligibility determination for access to classified 

information for an individual who has a current access eligibility based upon the requisite 

investigation (i.e. ANACI, NACLC, SSBI, or SSBI-PR) 

 

For the purpose of determining eligibility for access to classified information, to include highly 

sensitive programs (i.e. SCI, SAPs and Q), as the gaining activity/program for an individual who 

has current access eligibility with another Federal agency or program: 

• you cannot request the individual to complete a new security questionnaire; 

• you cannot review existing background investigations for the individual; 

• you cannot review existing security questionnaires for the individual; 

• you cannot initiate any new investigative checks; 

unless one or more of the questions below can be answered in the affirmative. 

Items 1 and 2 and 4 through 6 above can be verified by querying OPM’s Clearance Verification 

System (CVS), the Department of Defense’s Joint Personnel Adjudication System (JPAS), or the 

Intelligence Community’s Scattered Castles database. If you do not have on-line access to the 

appropriate database, or if the record is otherwise incomplete, you can fax an “Inter-Agency 

Clearance Verification Request” to the appropriate agency. The request form and appropriate fax 

numbers can be found at: https://opmis.xsp.org

29
30

_________________ 

Note 1 – An investigation for SAP access will be considered current if it is no more than five years 

old (seven years old if a periodic reinvestigation was submitted prior to expiration of the 

investigation and is currently pending), regardless of the classification level. 

Note 2 – Under such circumstances, only additional – not duplicative – investigative or adjudicative 

procedures will be completed. 

Note 3 – For purposes of reciprocity, all components of the Department of Defense to include the 

Military Departments and Defense Agencies shall be considered one agency. 

Note 4 – Under such circumstances, a current SF86, an SF 86C, or pen/ink changes to an existing 

SF 86 can be required. 

Note 5 –You can review an existing background investigation for the individual and/or request an 

investigative check only if the SF 86 or SF 86C contains new substantive information of security 

concern not previously considered in the prior SAP access eligibility determination or the last 

security clearance adjudication and could serve as the basis for disqualification. New substantive 

information will be adjudicated by a CAF in accordance with national adjudicative guidelines. 
31

INTELLIGENCE REFORM AND TERRORISM PREVENTION 

ACT OF 2004 (Public Law No: 108-458)

TITLE III—SECURITY CLEARANCES 

SEC. 3001. SECURITY CLEARANCES. 

(a) DEFINITIONS.—In this section: 

(1) The term ‘‘agency’’ means— 

(A) an executive agency (as that term is defined in section 105 of title 5, United States Code); 

(B) a military department (as that term is defined in section 102 of title 5, United States Code); and 

(C) an element of the intelligence community. 

(2) The term ‘‘authorized investigative agency’’ means an agency designated by the head of the 

agency selected pursuant to subsection (b) to conduct a counterintelligence investigation or 

investigation of persons who are proposed for access to classified information to ascertain whether 

such persons satisfy the criteria for obtaining and retaining access to such information. 

 

(3) The term ‘‘authorized adjudicative agency’’ means an agency authorized by law, regulation, or 

direction of the Director of National Intelligence to determine eligibility for access to classified 

information in accordance with Executive Order 12968. 

(4) The term ‘‘highly sensitive program’’ means— 

(A) a government program designated as a Special Access Program (as that term is defined in 

section 4.1(h) of Executive Order 12958 or any successor Executive order); 

or 

(B) a government program that applies restrictions required for— 

(i) restricted data (as that term is defined in section 11 y. of the Atomic Energy Act of 1954 (42 

U.S.C. 2014(y)); or 

(ii) other information commonly referred to as ‘‘sensitive 

compartmented information’’. 

(5) The term ‘‘current investigation file’’ means, with respect to a security clearance, a file on an 

investigation or adjudication that has been conducted during— 

(A) the 5-year period beginning on the date the security clearance was granted, in the case of a Top 

Secret Clearance, or the date access was granted to a highly sensitive program; 

(B) the 10-year period beginning on the date the security clearance was granted in the case of a 

Secret Clearance; 

And 
32

(C) the 15-year period beginning on the date the security clearance was granted in the case of a 

Confidential Clearance. 

(6) The term ‘‘personnel security investigation’’ means any investigation required for the purpose 

of determining the eligibility of any military, civilian, or government contractor personnel to access 

classified information. 

(7) The term ‘‘periodic reinvestigations’’ means investigations conducted for the purpose of 

updating a previously completed background investigation— 

(A) every 5 years in the case of a top secret clearance or access to a highly sensitive program; 

(B) every 10 years in the case of a secret clearance; 

Or 

(C) every 15 years in the case of a Confidential Clearance. 

(8) The term ‘‘appropriate committees of Congress’’ means— 

(A) the Permanent Select Committee on Intelligence and the Committees on Armed Services, 

Homeland Security, Government Reform, and the Judiciary of the House of Representatives; and 

(B) the Select Committee on Intelligence and the Committees on Armed Services, Homeland 

Security and Governmental Affairs, and the Judiciary of the Senate. 

(b) SELECTION OF ENTITY.—Not later than 90 days after the date of the enactment of this Act, 

the President shall select a single department, agency, or element of the executive branch to be 

responsible for— 

(1) directing day-to-day oversight of investigations and adjudications for personnel security 

clearances, including for highly sensitive programs, throughout the United States Government; 

(2) developing and implementing uniform and consistent policies and procedures to ensure the 

effective, efficient, and timely completion of security clearances and determinations for access to 

highly sensitive programs, including the standardization of security questionnaires, financial 

disclosure requirements for security clearance applicants, and polygraph policies 

and procedures; 

(3) serving as the final authority to designate an authorized investigative agency or authorized 

adjudicative agency; 

(4) ensuring reciprocal recognition of access to classified information among the agencies of the 

United States Government, including acting as the final authority to arbitrate and resolve disputes 

involving the reciprocity of security clearances and access to highly sensitive programs pursuant to 

subsection (d); 

(5) ensuring, to the maximum extent practicable, that sufficient resources are available in each 

agency to achieve clearance and investigative program goals; and 
33

(6) reviewing and coordinating the development of tools and techniques for enhancing the conduct 

of investigations and granting of clearances. 

(c) PERFORMANCE OF SECURITY CLEARANCE INVESTIGATIONS.— 

(1) Notwithstanding any other provision of law, not later than 180 days after the date of the 

enactment of this Act, the President shall, in consultation with the head of the entity selected 

pursuant to subsection (b), select a single agency of the executive branch to conduct, to the 

maximum extent practicable, security clearance investigations of employees and contractor 

personnel of the United States Government who require access to classified information and to 

provide and maintain all security clearances of such employees and contractor personnel. The head 

of the entity selected pursuant to subsection (b) may designate other agencies to conduct 

such investigations if the head of the entity selected pursuant to subsection (b) considers it 

appropriate for national security and efficiency purposes. 

(2) The agency selected under paragraph (1) shall— 

(A) take all necessary actions to carry out the requirements of this section, including entering into a 

memorandum of understanding with any agency carrying out responsibilities relating to security 

clearances or security clearance investigations before the date of the enactment of this Act; 

(B) as soon as practicable, integrate reporting of security clearance applications, security clearance 

investigations, and determinations of eligibility for security clearances, with the database required 

by subsection (e); and 

(C) ensure that security clearance investigations are conducted in accordance with uniform 

standards and requirements established under subsection (b), including uniform security 

questionnaires and financial disclosure requirements. 

(d) RECIPROCITY OF SECURITY CLEARANCE AND ACCESS DETERMINATIONS. 

—(1) All security clearance background investigations and determinations completed by an 

authorized investigative agency or authorized adjudicative agency shall be accepted by all agencies. 

(2) All security clearance background investigations initiated by an authorized investigative agency 

shall be transferable to any other authorized investigative agency. 

(3)(A) An authorized investigative agency or authorized adjudicative agency may not establish 

additional investigative or adjudicative requirements (other than requirements for the conduct of a 

polygraph examination) that exceed requirements specified in Executive Orders establishing 

security requirements for access to classified information without the approval of the head of the 

entity selected pursuant to subsection (b). 

(B) Notwithstanding subparagraph (A), the head of the entity selected pursuant to subsection (b) 

may establish such additional requirements as the head of such entity considers necessary for 

national security purposes. 

(4) An authorized investigative agency or authorized adjudicative agency may not conduct an 

investigation for purposes of determining whether to grant a security clearance to an individual 

where a current investigation or clearance of equal level already exists or has been granted by 

another authorized adjudicative agency. 
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(5) The head of the entity selected pursuant to subsection (b) may disallow the reciprocal 

recognition of an individual security clearance by an agency under this section on a case-by-case 

basis if the head of the entity selected pursuant to subsection (b) determines that such action is 

necessary for national security purposes. 

(6) The head of the entity selected pursuant to subsection (b) shall establish a review procedure by 

which agencies can seek review of actions required under this section. 

(e) DATABASE ON SECURITY CLEARANCES.—(1) Not later than 12 months after the date of 

the enactment of this Act, the Director of the Office of Personnel Management shall, in cooperation 

with the heads of the entities selected pursuant to subsections (b) and (c), establish and commence 

operating and maintaining an integrated, secure, database into which appropriate data relevant to the 

granting, denial, or revocation of a security clearance or access pertaining to military, civilian, or 

government contractor 

personnel shall be entered from all authorized investigative and adjudicative agencies. 

(2) The database under this subsection shall function to integrate information from existing Federal 

clearance tracking systems from other authorized investigative and adjudicative agencies into a 

single consolidated database. 

(3) Each authorized investigative or adjudicative agency shall check the database under this 

subsection to determine whether an individual the agency has identified as requiring a security 

clearance has already been granted or denied a security clearance, or has had a security clearance 

revoked, by any other authorized investigative or adjudicative agency. 

(4) The head of the entity selected pursuant to subsection (b) shall evaluate the extent to which an 

agency is submitting information to, and requesting information from, the database under this 

subsection as part of a determination of whether to certify the agency as an authorized investigative 

agency or authorized adjudicative agency. 

(5) The head of the entity selected pursuant to subsection (b) may authorize an agency to withhold 

information about certain individuals from the database under this subsection if the head of the 

entity considers it necessary for national security purposes. 

(f) EVALUATION OF USE OF AVAILABLE TECHNOLOGY IN CLEARANCE 

INVESTIGATIONS AND ADJUDICATIONS.— 

(1) The head of the entity selected pursuant to subsection (b) shall evaluate the use of available 

information technology and databases to expedite investigative and adjudicative processes for all 

and to verify standard 

information submitted as part of an application for a security clearance. 

(2) The evaluation shall assess the application of the technologies 

described in paragraph (1) for— 

(A) granting interim clearances to applicants at the secret, top secret, and special access program 

levels before the completion of the appropriate full investigation; 

(B) expediting investigations and adjudications of security clearances, including verification of 

information submitted by the applicant; 
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(C) ongoing verification of suitability of personnel with security clearances in effect for continued 

access to classified information; 

(D) use of such technologies to augment periodic reinvestigations; 

(E) assessing the impact of the use of such technologies on the rights of applicants to verify, correct, 

or challenge information obtained through such technologies; and 

(F) such other purposes as the head of the entity selected pursuant to subsection (b) considers 

appropriate. 

(3) An individual subject to verification utilizing the technology described in paragraph (1) shall be 

notified of such verification, shall provide consent to such use, and shall have access to data being 

verified in order to correct errors or challenge information the individual believes is incorrect. 

(4) Not later than one year after the date of the enactment of this Act, the head of the entity selected 

pursuant to subsection (b) shall submit to the President and the appropriate committees of Congress 

a report on the results of the evaluation, including recommendations on the use of technologies 

described in paragraph (1). 

(g) REDUCTION IN LENGTH OF PERSONNEL SECURITY CLEARANCE 

PROCESS.— 

(1) The head of the entity selected pursuant to subsection (b) shall, within 90 days of selection 

under that subsection, develop, in consultation with the appropriate committees of Congress and 

each authorized adjudicative agency, a plan to reduce the length of the personnel security clearance 

process. 

(2)(A) To the extent practical the plan under paragraph (1) shall require that each authorized 

adjudicative agency make a determination on at least 90 percent of all applications for a personnel 

security clearance within an average of 60 days after the date of receipt of the completed application 

for a security clearance by an authorized investigative agency. Such 60-day average period shall 

include— 

(i) a period of not longer than 40 days to complete the investigative phase of the clearance review; 

and 

(ii) a period of not longer than 20 days to complete the adjudicative phase of the clearance review. 

(B) Determinations on clearances not made within 60 days shall be made without delay. 

(3)(A) The plan under paragraph (1) shall take effect 5 years after the date of the enactment of this 

Act. 

(B) During the period beginning on a date not later than 2 years after the date after the enactment of 

this Act and ending on the date on which the plan under paragraph (1) takes effect, each authorized 

adjudicative agency shall make a determination on at least 80 percent of all applications for a 

personnel security clearance pursuant to this section within an average of 120 days after the date of 

receipt of the application for a security clearance 

by an authorized investigative agency. Such 120-day average period shall include— 
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(i) a period of not longer than 90 days to complete the investigative phase of the clearance review; 

and 

(ii) a period of not longer than 30 days to complete the adjudicative phase of the clearance review. 

(h) REPORTS.—(1) Not later than February 15, 2006, and annually thereafter through 2011, the 

head of the entity selected pursuant to subsection (b) shall submit to the appropriate committees of 

Congress a report on the progress made during the preceding year toward meeting the requirements 

of this section. 

(2) Each report shall include, for the period covered by such 

report— 

(A) the periods of time required by the authorized investigative agencies and authorized 

adjudicative agencies for conducting investigations, adjudicating cases, and granting clearances, 

from date of submission to ultimate disposition and notification to the subject and the subject’s 

employer; 

(B) a discussion of any impediments to the smooth and timely functioning of the requirements of 

this section; and 

(C) such other information or recommendations as the head of the entity selected pursuant to 

subsection (b) considers appropriate. 

(i) AUTHORIZATION OF APPROPRIATIONS.—There is authorized to be appropriated such 

sums as may be necessary for fiscal year 2005 and each fiscal year thereafter for the 

implementation, maintenance, and operation of the database required by subsection (e).