Personnel Security Clearances: An Outcome-Focused Strategy Is Needed to Guide Implementation of the Reformed Clearance Process
Published: 2009-05-19T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Personnel security clearances are used to verify that national security information--which in some cases could cause exceptionally grave damage to national security if disclosed--is entrusted only to those who have proven reliability and loyalty to the nation. In response to long-standing problems with timeliness and backlogs, Congress mandated clearance reforms as part of the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA), and since 2005 the Department of Defense's (DOD) clearance program has remained on GAO's high-risk list despite improvements in timeliness. In 2007, a Joint Reform Team, led by the Office of Management and Budget (OMB), was established to improve the clearance process across the government. GAO was asked to review the extent to which reform efforts (1) align with key practices for organizational transformations and (2) address identified factors for reforming the personnel security clearance process. To assess these objectives, GAO compared joint reform reports to key transformation practices and essential factors for reform.
section_title: What GAO Found
paragraphs: Initial joint reform efforts have, in part, aligned with key practices for organizational transformation, such as having committed leadership and a dedicated implementation team, but reports issued by the Joint Reform Team do not provide a strategic framework that contains important elements of successful transformation, including long-term goals with related outcome-focused performance measures to show progress, or identify obstacles to progress and possible remedies. To communicate plans of the reform efforts, the Joint Reform Team issued three reports, including an initial reform report in April 2008 that presented a new 7-step process design, a December 2008 update, and a March 2009 Enterprise Information Technology Strategy. Consistent with practices that GAO has previously identified, the executive branch established a Performance Accountability Council to achieve reform goals, drive implementation, and oversee the reform. Membership on this council currently includes senior executive leaders from 11 federal agencies. Further, an executive order designates OMB's Deputy Director for Management as the chair of this council. However, it is difficult to gauge progress of reform, or determine if corrective action is needed, because the council, through the Joint Reform Team, has not established a method for evaluating the progress of the reform efforts. In the absence of a strategic framework that is outcome focused, with clearly defined performance measures, the Joint Reform Team is not in a position to demonstrate to decision makers the extent of progress that it is making toward achieving its desired outcomes. The personnel security clearance joint reform reports that GAO reviewed collectively do begin to address essential factors for reforming the security clearance process, which represents positive steps. GAO's prior work and IRTPA identified several factors key to reforming the clearance process. These include (1) developing a sound requirements determination process, (2) engaging in governmentwide reciprocity, (3) building of quality into every step of the process, (4) consolidating information technology, and (5) identifying and reporting long-term funding requirements. However, the Joint Reform Team's informationtechnology strategy does not yet define roles and responsibilities for implementing a new automated capability which is intended to be a cross-agency collaborative initiative. GAO's prior work has stressed the importance of defining these roles and responsibilities when initiating cross-agency initiatives. Also, the joint reform reports do not contain any information on initiatives that will require funding, determine how much they will cost, or identify potential funding sources. Without long-term fundingrequirements, decision makers in both the executive and legislative branches will lack important information for comparing and prioritizing proposals for reforming the clearance processes. The reform effort's success will be dependent upon the extent to which the Joint Reform Team is able to fully address these key factors moving forward.

section_title: Letter
paragraphs: Personnel security clearances are used to verify that national security  information—which in some cases could cause exceptionally grave  damage to U.S. national defense or foreign relations if disclosed—is  entrusted only to individuals who have proven reliability and loyalty to the  nation. Following the terrorist attacks on September 11, 2001, the nation’s  defense and intelligence needs grew, prompting increased demand for  personnel with security clearances. According to officials from the Joint  Reform Team, about 2.4 million people—excluding some of those with  clearances who work in areas of national intelligence—currently hold  clearances, and the Office of Personnel Management (OPM) conducted  about 750,000 national security investigations in fiscal year 2008. We have  previously reported on delays and backlogs in security clearance  processing, lack of reciprocity, and incomplete investigations. As a result  of these long-standing issues, we have designated the Department of  Defense’s (DOD) personnel security clearance program a high-risk area  since 2005.
In response to concerns about delays in processing clearances and other  issues, Congress set goals and established requirements for improving the  clearance process in the Intelligence Reform and Terrorism Prevention  Act of 2004 (IRTPA). Those requirements include, among other things,  improving the timeliness of the clearance process, achieving interagency  reciprocity, establishing an integrated database to track investigative and  adjudicative information, and evaluating available technology for  investigations and adjudications. While DOD and other executive branch  agencies responsible for investigating or adjudicating clearances for  federal personnel, military servicemembers, and government contractors  have made significant progress in improving timeliness and evaluating the  use of available technology in clearance processing, problems related to  the quality of security clearance investigations and adjudication  determinations, reciprocity of clearance determinations, and information  technology persist.
In 2007, the Joint Reform Team—which currently consists of cognizant  entities within the Office of Management and Budget (OMB), Office of  Personnel Management (OPM), Office of the Director of National  Intelligence (ODNI), and the Under Secretary of Defense (Intelligence)— was established by the Director of National Intelligence through a  Memorandum of Agreement to execute joint reform efforts to achieve  IRTPA timeliness goals and improve the processes related to granting  security clearances and determining suitability for government  employment. In its April 2008 report, the Joint Reform Team called for an  executive branch governance structure to ensure accountability and  sustain reform momentum. Subsequently, in June 2008, Executive Order  13467 established a Suitability and Security Clearance Performance  Accountability Council, commonly known as the Performance  Accountability Council, to be the governmentwide governance structure  responsible for driving implementation and overseeing these reform  efforts. Furthermore, the order appointed the Deputy Director for  Management at OMB as the chair of the council and designated Executive  Agents for Suitability and Security. The Joint Reform Team continues to  work on the reform effort under the Performance Accountability Council  by providing progress reports, recommending research priorities, and  overseeing the development and implementation of an information  technology strategy, among other things. In addition to its April 2008  report, the Joint Reform Team provided two other key reports, which  collectively communicate the reform effort’s plans for reforming the  security clearance process. First, in December 2008, the Joint Reform  Team issued a report on the progress of the reform efforts and provided  further details on the plans to implement reforms. Most recently, in March  2009, the Joint Reform Team finalized an Enterprise Information  Technology Strategy to support the reformed security and suitability  process and its associated milestones described in the April and December  reports. Figure 1 highlights key events related to security clearance  ance  reform.  reform.
Congressional oversight through hearings held by the Subcommittee on  Intelligence Community Management, House Permanent Select Committee  on Intelligence, in February and July 2008 has helped focus attention on  the need for security clearance reform. In addition, the Chairman of the  House Permanent Select Committee on Intelligence and the Chairwoman  of the Subcommittee on Intelligence Community Management asked us to  examine the ongoing reforms relative to key practices GAO has used to  evaluate other reform efforts, and to review the criteria that the executive  branch is using to assess the effectiveness of its efforts. Specifically, in this  report we address the following questions: (1) To what extent are joint  efforts to reform the personnel security clearance process consistent with  key practices—including setting outcome-focused implementation goals to  show progress—that GAO has identified for successful organizational  transformations? (2) To what extent do the three security clearance joint  reform reports address essential factors for reforming the security  clearance process?
To assess the extent to which efforts to reform the personnel security  clearance process are consistent with key practices that GAO has  identified for successful organizational transformations, we collected and  analyzed reports and documents related to the reform effort. We also  conducted interviews with relevant officials from the Performance  Accountability Council, the Joint Reform Team, and other federal agencies  involved in the reform effort. We then compared our analysis of the reform  efforts with key practices for organizational transformations. To assess the  extent to which security clearance reform plans address essential factors  for reforming the security clearance process, we reviewed the April and  December 2008 progress reports and the March 2009 information  technology strategy report, which collectively communicate the reform  plans developed since the establishment of the Joint Reform Team in 2007.  We then conducted interviews to discuss those plans with agency officials  from the Performance Accountability Council, the Joint Reform Team, and  agencies affected by reform efforts. We also analyzed additional guidance  and executive branch policies, including executive orders and recently  issued federal investigative standards. Specifically, we compared the  reports to factors we previously identified and two additional criteria  established in IRTPA that are essential to reforming the clearance  process. We conducted this performance audit from August 2008 through  May 2009 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Since 1997, federal agencies have followed a common set of personnel  security investigative standards and adjudicative guidelines for  determining whether servicemembers, federal workers, private industry  personnel, and others are eligible to receive security clearances. Security  clearances are required for access to certain national security information,  which is classified at one of three levels: top secret, secret, or confidential.  The level of classification denotes the degree of protection required for  information and the amount of damage that unauthorized disclosure could  reasonably cause to national security. The degrees of expected damage  that unauthorized disclosure could reasonably be expected to cause are  “exceptionally grave damage” for top secret information, “serious damage”  for secret information, and “damage” for confidential information.
We have previously reported problems—including significant delays in  processing clearances—associated with DOD’s security clearance  processes, and in 2005, 2007, and again in 2009, we identified not only  delays in completing the end-to-end clearance processing but also  incomplete investigative and adjudicative reports. More recently, we  reported that although the executive branch has met current IRTPA  timeliness requirements—under which adjudicative agencies are to make a  determination on at least 80 percent of all applications for a security  clearance within 120 days, on average, after the date of receipt of the  application—executive branch reports to Congress do not capture the full  range of time that OPM and DOD took to make clearance determinations.  Further, we found that those reports provided decision makers little  information on quality, and that the majority of OPM-provided  investigative reports, which DOD adjudicators (agency employees who  decide whether to grant a clearance to an applicant based on the  investigation and other information) used to grant initial top secret  clearances in July 2008, were missing required documentation.
In June 2005, the President issued an executive order as part of the  administration’s efforts to improve the security clearance process and to  implement the statutory clearance requirements in IRTPA. This order  tasked the Director of OMB with a variety of functions in order to ensure  that agency processes relating to determining eligibility for access to  classified national security information were appropriately uniform,  centralized, efficient, effective, timely, and reciprocal. Since 2005, OMB’s  former Deputy Director for Management has taken several actions to  improve the security clearance process. These actions include establishing  an interagency working group to improve the reciprocal acceptance of  clearances issued by other agencies and taking a lead role in preparing a  November 2005 plan to improve the timeliness of personnel security  clearance processes governmentwide. The November 2005 plan included  quarterly timeliness goals for initial investigations of clearances from  November 2005 through December 2006 and an action plan for improving  the security clearance process to meet the requirements of IRTPA, such as  timeliness, reciprocity, and the establishment of an integrated database to  track investigative and adjudicative information.
The Joint Reform Team submitted its first reform plan to the President on  April 30, 2008; the plan presented a proposed transformed security  clearance and suitability process. (See fig. 2.) The plan also presented a  new 7-step process for determining eligibility: (1) validating the need for  security or suitability investigation and adjudication, (2) an electronic  application, (3) automated records checks, (4) electronic adjudication,   (5) an enhanced subject interview, (6) an expandable focused  investigation, and (7) continuous evaluation of persons with security  clearances. The key differences between this design and the current  process are more extensive use of information technology from beginning  to end and a more customized approach to investigations through in-depth  personal interviews and targeted use of human investigative resources.
The Joint Reform Team’s April 2008 plan also proposed a new executive  branch governance structure for coordinating security clearance and  suitability decisions, and on June 30, 2008, the President issued Executive  Order 13467 that established the Performance Accountability Council. In  accordance with Executive Order 13467, the Performance Accountability  Council is accountable to the President to achieve reform goals, drive  implementation, and oversee clearance reform. The council comprises  representatives from 11 executive agencies. (See fig. 3.) The Joint Reform  Team—composed of staff from OPM, DOD, and ODNI—is not formally  part of the governance structure established by Executive Order 13467 but  in practice reports to the Performance Accountability Council and is  responsible for policy, process, and information technology in accordance  with the council’s charter. In addition, two subcommittees at the working  level also report to the council. The Training Subcommittee is developing  training standards that will be used to help align security and suitability  processes, and the Performance Measurement and Management  Subcommittee is developing performance metrics that the council will use  to assess the timeliness and quality of the investigative and adjudicative  processes, among other things. Following implementation of the  performance metrics, subcommittee members will continue to assess the  metrics and update them to inform policymakers on the reform process.
section_title: Initial Reform Efforts Have Partially Aligned with Key Practices but Lack a Fully Developed Strategic Framework with Outcome-Focused Performance Measures to Show Progress
paragraphs: Although initial reform efforts have, in part, aligned with established key  practices for organizational transformation, it is difficult to assess the  progress of reform or determine if corrective action is needed. In  September 2002, GAO convened a forum to identify and discuss practices  and lessons learned from major private and public sector organizational  mergers, acquisitions, and transformations that can serve as a guide as  federal agencies transform their processes in response to governance  challenges. Consistent with some of these key practices, the  Performance Accountability Council’s membership currently includes  senior executive leaders from 11 federal agencies. However, because the  reform efforts are missing important elements of a strategic framew that are also consistent with the Government Performance and Results of 1993 (GPRA), such as long-term goals with related outcome-fo cused  performance measures that show progress or identify obstacles to  progress and possible remedies, the reform effort is not able to  demonstrate incremental progress toward strategic goals, and the effort  runs the risk of losing momentum and governmentwide buy-in.
subsections: section_title: Key Practices for Large- Scale Transformations
paragraphs: Planning and implementing a large-scale transformation such as reforming  the personnel security clearance process is not a simple endeavor and  requires the concentrated efforts of both leadership and employees across  government. Participants in a forum GAO convened in 2002 generally  agreed on a number of practices that can serve as a guide for  organizational mergers, acquisitions, and transformations, including  committed leadership, a mission with strategic goals, implementation  goals and a timeline, and a formal communication strategy. These key  practices, among others, are as follows:    Ensure that top leadership drives the transformation. Leadership must set  the direction, pace, and tone and provide a clear, consistent rationale that  brings everyone together behind a single mission.
Dedicate an implementation team to manage the transformation process.
A strong and stable team is important to ensure that the transformation  receives the needed attention to be sustained and successful.
Establish a coherent mission and integrated strategic goals to guide the  transformation. Together, these define the culture and serve as a vehicle  for employees to unite and rally around.
Focus on a key set of principles and priorities at the outset of the  transformation. A clear set of principles and priorities serves as a  framework to help the organization create a new culture and drive  employee behaviors.
Use the performance management system to define responsibility and  ensure accountability for change. This system shows how team, unit, and  individual performance can contribute to overall organizational results.
Set implementation goals and a timeline to build momentum and show  progress from day one. Goals and a timeline are essential because the  transformation could take years to complete.
Establish a communication strategy to create shared expectations and  report related progress. The strategy must reach out to employees,  customers, and stakeholders and engage them in a two-way exchange.  Involve employees to obtain their ideas and gain their ownership for the  transformation. Employee involvement strengthens the process and allows  employees to share their experiences and shape policies.
section_title: The Reform Effort Has Benefited from Committed Leadership and a Dedicated Implementation Team, but Sustainment Is Key
paragraphs: High-level leaders—including senior officials from OMB, DOD, OPM,  ODNI, and seven other federal agencies—have made a commitment to the  governmentwide security clearance reform efforts. In a February 2008  memo, the President directed OMB, OPM, ODNI, and DOD to submit an  initial security clearance reform proposal by April 30, 2008. Executive  Order 13467 further demonstrated leadership commitment to security  clearance reform by creating a governance structure—the Performance  Accountability Council. The council is accountable to the President to  achieve the goals of reform stated in Executive Order 13467, drive  implementation, and sustain reform momentum. The council’s governance  structure is permanent, unless it is altered by a new executive order or  law. The Chair of the council provides direction and has control over its  functions and the authority to make final decisions and appoint members.  The council has met monthly since July 2008 to share information and  make decisions to drive the reform process, although, as of this report’s  issue date, the chair position, which is held by OMB’s Deputy Director for  Management, has remained vacant since January 2008, and no presidential  appointee has yet been named. Without continued committed leadership  and sustained support from the new administration, it will be difficult to  complete the reform efforts and sustain the interagency collaboration that  is needed to move this effort forward.
In addition to high-level leadership, the reform effort has benefited from a  dedicated implementation team to manage the transformation process  from the beginning. The Joint Reform Team—composed of staff from  multiple agencies, including OMB, DOD, OPM, and ODNI—is a dedicated  team that works full-time on security clearance reform. The Joint Reform  Team is responsible for day-to-day management of the reform effort, and it  produces the key reports to the President that update the status of the  efforts and lay out future plans, such as the April and December 2008  reports and the March 2009 information technology strategy report. Within  the reform team, four senior executives—one from each agency—guide  the effort to streamline and modernize the security clearance process.  Under the senior executives are senior leaders who manage the reform  effort on a daily basis, including approximately 17 full-time staff  members—some with backgrounds in personnel security and others with  DOD business transformation experience—who work in the areas of  policy, process improvement, and information technology development.  These staff members are “on loan” from the parent agencies, and although  the Joint Reform Team currently does not have an end date, officials told  us that they expect the team to stay in place at least through 2010.
section_title: The Reform Effort Lacks a Strategic Framework That Includes Important Elements of a Successful Transformation
paragraphs: It is unclear how the planned transformation of the security clearance  process will identify success or how long the reform effort will take  because the effort lacks a strategic framework that includes important  elements of successful transformations such as a coherent mission  statement, long-term strategic goals, outcome-focused performance  measures, and a comprehensive communication strategy.
Mission and strategic goals: Neither the Joint Reform Team’s April nor  December 2008 reports to the President define the mission or strategic  goals of the reform effort. In its April 2008 report, the Joint Reform Team  articulated principles for the reformed process: (1) more relevant  information is collected and validated at the beginning of the security  clearance process, (2) automation is used to make the process faster,      (3) field investigative activity is focused, (4) risk decisions rely on modern  analytic methods rather than practices that avoid risk, (5) relevant data are  better used for subsequent hiring and clearing decisions, and                     (6) continuous evaluation techniques replace periodic reinvestigations.  These principles help explain the purpose of the reformed 7-step clearance  process, but they do not articulate a mission statement that concisely  summarizes the main purposes for the reform effort’s major functions and  operations or strategic goals that encompass the long-term outcomes that  the governmentwide reform effort is intended to achieve. Strategic goals  explain what results are expected and when to expect those results,  should correspond to the purposes set forth in an organization’s mission  statement, and develop with greater specificity how the organization will  carry out its mission. Strategic goals cannot exist without a mission  statement to drive and tie them together.
In designing a new personnel security clearance system, GPRA may be a  useful resource for both the team designing the system and the  congressional committees overseeing the design and implementation.  GPRA provides a framework for strategic performance planning and  reporting intended to improve federal program effectiveness and hold  agencies accountable for achieving results. Agencies that effectively  implement GPRA’s results-oriented framework clearly establish  performance goals for which they will be held accountable, measure  progress toward those goals, determine strategies and resources to  effectively accomplish the goals, use performance information to make the  programmatic decisions necessary to improve performance, and formally  communicate results in performance reports.
Furthermore, in a successful transformation effort, developing,  communicating, and constantly reinforcing the effort’s mission and  strategic goals helps employees understand how their positions fit in with  the new organization and what they need to do differently to help the new  organization achieve success. When we asked leaders, staff members, and  stakeholders of the reform effort to define the reform effort’s strategic  goals, they identified different goals, such as IRTPA requirements and  making the security clearance process more timely, more cost-efficient,  and higher quality. Moreover, strategic goals are an integral part of the  performance management systems for leaders and employees. Although  senior leaders from the Joint Reform Team told us that their agencies  respective performance management systems assessed their performance  according to the contributions they make to the reform efforts, without a  clear mission and strategic goals to align with individual expectations,  employees are not necessarily held accountable for whether they are  achieving desired results.
Timeline for implementation and outcome-focused performance  measures: Although the December 2008 report contains a timeline for  implementation of aspects of the reformed process through December  2009 and cites estimated operational dates for elements of the reformed  process through 2010, leaders of the Joint Reform Team acknowledged  that they are in the initial stages of reaching out to agencies across the  federal government, including the intelligence agencies, to determine how  and when the reformed process will be implemented governmentwide. In  addition, the reform effort currently lacks outcome-focused performance  measures to assess whether it is achieving the desired results (i.e., its  strategic goals). Consequently, the leaders of the reform effort—as well as  Congress and the administration—have no way of measuring whether the  reform effort is making progress toward resolving long-standing problems  with the security clearance process, and the effort runs the risk of losing  momentum. According to key practices for transformations,  implementation goals and a timeline are essential to show progress from  day one because transformations could take many years to complete.
Although neither the Joint Reform Team nor the Performance  Accountability Council developed metrics to assess the progress of the  reform effort, the key reform reports discuss several metrics that the  council developed to evaluate factors like timeliness and quality once the  reformed process is implemented. The council is working to finalize these  metrics. Concerning timeliness, the reports describe the IRTPA  requirement to complete 90 percent of security clearance determinations  within an average of 60 days, to the extent practical, as their target.  According to the key reports, the Performance Accountability Council  established measures for end-to-end, initiation, investigation, and  adjudication times. Concerning quality, the reports describe two  measures that the council is developing. First, the council developed a  measure of investigative quality that tracks the number of deficient  investigative cases that adjudicators return for further investigation. We  have previously reported that deficient cases alone are not a valid  indicator of quality because adjudication officials told us that they were  reluctant to return incomplete investigations as they anticipated this could  lead to delays. Second, the reform effort plans to require adjudicators to  complete a survey about the quality of investigations. Clearly defined  timeliness and quality metrics can improve the security clearance process  by enhancing oversight of the time required to process security clearances  and the quality of the investigation and adjudicative decisions. Further, in  our May 2009 report on DOD’s personnel clearances, we recommended  that OMB provide Congress with results of metrics on comprehensive  timeliness and the quality of investigations and adjudications as part of the  IRTPA-required annual reports on personnel security clearances. Until  the Performance Accountability Council finishes developing metrics to  evaluate efficiency and effectiveness of the clearance process, Congress  and the council will be limited in their ability to effectively oversee the  reformed process and identify problems with delays in the processing of  clearances or inadequate quality.
Formal communication strategy and stakeholder involvement: The  Performance Accountability Council and Joint Reform Team have  communicated with executive branch agencies that request and grant  security clearances and suitability determinations, but they lack a formal,  comprehensive communication strategy that reaches out to their  stakeholders and engages them in the reform process. According to  transformation key practices, a two-way exchange between leadership,  employees, and stakeholders early and often helps build trust and shared  expectations. The Joint Reform Team used its April and December 2008  reports as its primary vehicles to communicate plans for the new process  with all stakeholders. In addition, the council holds monthly meetings and  updates high-level leadership from its 11 member agencies on the progress  of the reform efforts. Further, senior reform leaders have communicated  with stakeholders governmentwide through a series of briefings that  involve senior officials and personnel. Still, some stakeholders at agencies  not represented on the Joint Reform Team told us that they are unclear  how they will implement the new process. For example, they were not  sure how the reform would affect their day-to-day operations or if they  would be responsible for funding some of the automated aspects of the  reformed process. More recently, in January 2009, the Joint Reform Team  held a governmentwide meeting to assess agencies’ ability to implement  the new process. The Joint Reform Team administered a questionnaire,  which included questions regarding federal agencies’ ability to use existing  information technology systems to process clearances. Except for the  January 2009 meeting and questionnaire, the communication efforts have  not promoted the kind of two-way communication necessary to ensure the  successful completion of the transformation. Without a formal  communication strategy for reaching out to stakeholders, including a built- in mechanism for two-way communication between those leading reform  efforts and the stakeholders, the reform effort risks undermining support  for the transformation by creating uncertainty and mistrust among  stakeholders about planned changes. In addition, the Joint Reform Team  may not be able to identify barriers or obstacles to achieving their goals  and identify mitigation strategies.
section_title: Joint Reform Reports Have Begun to Address Factors That Are Critical to Reforming the Security Clearance Process
paragraphs: The joint reform reports—issued by the Joint Reform Team to the  President and signed by the former Deputy Director of Management at  OMB in his capacity as Chair of the Performance Accountability Council— include plans that begin to address factors that are critical to reforming  the security clearance process. Our prior work identified factors key to  reforming the clearance process, and IRTPA identified two additional  criteria, that are also essential to reforming the clearance process. These  factors include (1) a sound requirements determination process,               (2) governmentwide reciprocity, (3) the building of quality into every step  of the process, (4) consolidated information technology, and (5) the  identification and reporting of long-term funding requirements. Key  reports from the Joint Reform Team begin to address four of these  essential factors for reform, although they do not contain any information  on roles and responsibilities for the information technology strategy or  long-term funding requirements. Table 1 summarizes the results of our  comparison of the joint reform reports against these five factors for  reform.
As table 1 shows, the reform reports show that the Joint Reform Team is  in the process of addressing four out of five of these factors critical to  reforming the security clearance process:  Establish a sound requirement determination process: The key reform  reports begin to address the need for agencies to request the appropriate  number of clearances at the appropriate levels; however, the reports do  not provide a mechanism for ensuring that the number and level of  clearances being requested reflect the mission needs of the requesting  agencies. By establishing an initial phase in the revised clearance process  by which agencies will validate that each application and investigation  they request is required to carry out their missions, the reform team  expects to eliminate duplicative applications and investigations. If an  existing federal employee or contractor with an active security clearance  accepts a position that requires a clearance of the same level at a different  federal agency, the new agency is expected to first verify that the applicant  has an existing clearance. Additionally, the reports stress the importance  for agencies to request clearances at the appropriate clearance levels— that is, confidential, secret, or top secret—for their positions. However, we  have previously reported, for example, that a growing percentage of DOD  requests for clearances are at the top secret level. According to OPM, top  secret clearances require about 10 times more hours, in the current  clearance process, to investigate than secret or confidential clearances.  Further, each standard top secret investigation cost DOD $3,888 as part of  the current process. According to the Joint Reform Team, of the  approximately 2.4 million DOD civilians, military, and contractor  personnel who hold security clearances, approximately 387,000 of those  clearances are top secret. However, the reports do not require the  agencies to assess the numbers and levels of clearances needed to fulfill  their missions. Without a sound process for determining security clearance  requirements, clearance requests could result in wasteful spending of  government resources if clearances are requested at levels that are not  necessary to meet the needs of some missions. Conversely, if agencies or  military services do not request enough clearances at the appropriate  levels, they may not have enough staff with sufficient clearances to  manage their classified workloads.
Establish governmentwide reciprocity: One of the key reform reports  states that reciprocity—an agency’s acceptance of a clearance and access  level granted by another department, agency, or military service—will be  measured by the number of agencies that ask newly hired personnel, who  already have security clearances, to complete personnel security clearance  questionnaires and then request new investigations for those same  personnel. IRTPA states that all security clearance determinations shall be  accepted by all agencies, with limited exceptions when necessary for  national security purposes. According to one of the key reports, employers  or agencies are to check the appropriate databases to determine if  individuals selected for federal positions or to work as contractor  employees already have qualifying clearances or open investigations.  However, the reports do not contain any measures related to the  reciprocal acceptance of previous adjudications—which are the final  determinations as to whether to grant a clearance to an applicant.  Furthermore, the plans do not contain an enforcement mechanism to  ensure that agencies comply with reciprocity requirements, and no  information exists on who will monitor reciprocity or how noncompliant  agencies will be addressed. In addition, the key reform reports indicate  that the Performance Accountability Council is taking steps to make  investigations and adjudications more consistent across the government  by standardizing the training of investigators and adjudicators and  automating parts of the process. For example, the reports discuss the  development of core courses as well as a formalized certification for  investigators and adjudicators. According to senior leaders of the reform  effort, these steps will enable reciprocal acceptance of clearance decisions  governmentwide. However, the key reports do not address plans to  implement reciprocity among the intelligence agencies, which require  more information—such as a polygraph of the applicant as part of an  applicant’s investigation—than agencies that are outside the intelligence  community. Officials told us that they are in the initial phase of reaching  out to intelligence agencies to address their concerns. Until all federal  agencies begin to practice reciprocity of clearance investigations and  adjudications—barring specific concerns—unnecessarily duplicative  clearance investigations and adjudications will continue to slow the  investigative and adjudicative process for all clearances and waste  government resources.
Build quality into every step of the process: The key reform reports are  beginning to incorporate quality control mechanisms in certain steps of  the reformed 7-step security clearance process. For example, one step in  the reformed process is “e-Adjudication” which involves automated  electronic clearance decisions for applicants whose automated records  checks did not reveal any issues that require further investigation before  being forwarded to an adjudicator. According to key reform reports, to  build quality into e-Adjudication, DOD issued guidance in November 2008  that required DOD adjudicators to simultaneously adjudicate files  electronically (or automated) and manually (by a person reviewing an  investigation file) as part of initial implementation of electronic  adjudication. This simultaneous approach to adjudication is to evolve into  a long-term program for continuous assurance and quality control.  However, it is unclear how the reform team will incorporate quality into  the other six steps of the reformed process, such as the enhanced subject  interview (step 5 in the reformed process) in that the reform reports do  not describe how these interviews will be structured and monitored to  ensure consistency and quality control. Officials within various executive  branch agencies raised this as an area of concern, citing that the  information gathered during the interview and investigative portion of the  process is essential for making adjudicative decisions.
Develop and consolidate information technology: According to our  analysis of key reform reports, the reform effort is beginning to use  information technology to improve the clearance process. IRTPA requires  OMB to evaluate the use of available technology in security clearance  investigations and adjudications. To improve the security clearance  process, the Joint Reform Team conducted demonstration activities to  determine how to automate the process and has issued an Enterprise  Information Technology Strategy to support the advancement of the  reformed security and suitability process. This strategy provides a  framework for federal agencies to collaborate on leveraging existing  systems and capabilities currently in operation. In addition, this strategy is  intended to establish a new end-to-end governmentwide capability to  support the reformed 7-step security and suitability process. Agencies  requesting and investigating clearances are expected to use this new  automated application, adjudication, monitoring, and record-check  process, which the Joint Reform Team expects to improve the timeliness  of clearances governmentwide by the end of 2010, according to key  reports. The reform team is currently working with individual agencies to  assess their information technology capabilities and assist with the  development of agency information technology implementation plans to  determine how to transition all agencies to the automated capability  described in key reports. In addition, the Joint Reform Team is in the  process of weighing options for the architecture of the future automated  system that it is planning to implement throughout government during  2009 and 2010.
However, the strategy does not define the roles and responsibilities for the  agencies involved in the reform effort. Our prior work has stressed the  importance of defining clear roles and responsibilities before the  implementation of information processing systems. Establishing clearly  defined roles and responsibilities on a cross-agency initiative helps to  ensure that responsible agencies have a clear understanding of what they  are expected to contribute and produce in support of the initiative. These  roles and responsibilities for cross-agency programs are generally  documented in memorandums of understanding between agencies.  Because the Joint Reform Team has not established clear roles and  responsibilities for the agencies involved, it will be difficult to hold agency  leadership accountable and achieve a joint vision.
IRTPA also requires OPM to establish an integrated database that tracks  investigation and adjudication information, and authorizes the  appropriation of necessary funding for that database’s implementation.  However, at present, no single database exists, and the key reports that we  reviewed do not discuss any plans for meeting the single database  requirement. Executive branch agencies currently use three separate  database platforms (the Joint Personnel Adjudication System, Clearance  Verification System, and Scattered Castles) to house clearance  information. The Joint Reform Team’s December 2008 report discusses  plans to improve access to records through the Clearance Verification  System in order to enhance the reciprocity of investigations and clearance  determinations. However, it is not possible, according to senior reform  leaders, to determine the total number of personnel with security  clearances through any one of these platforms. The platforms are intended  to allow security professionals to search for information on individuals  who have clearances, but not to aggregate data on the total number of  clearance holders. Further, some officials we spoke with expressed  concerns about the potential security risks involved in the event of the  unauthorized disclosure of names and other sensitive information about  cleared intelligence agency personnel contained in Scattered Castles.  Currently the Joint Reform Team is working with intelligence agencies to  develop a solution that aligns with IRTPA while addressing those agencies’  concerns. However, this outreach is in its early stages, and according to  reform team members, it will take time to develop an information  technology solution for sharing information between classified and  unclassified databases.
Provide Congress with long-term funding requirements: Although senior  reform leaders have stated that primary reform costs will be paid by DOD  and OPM, key reform reports do not contain any information regarding the  Joint Reform Team’s plans to identify what initiatives require funding,  specify how much funding will be required, specify when funding will be  needed and how it will be budgeted, or estimate any potential cost savings  that could result from the reformed system. Further, some agencies have  expressed concern that they will be responsible for funding elements of  reform from within their budgets, yet these organizations do not know  what they may have to fund or where the money will come from. Without  long-term funding requirements, leaders of the reform effort will be unable  to compare and prioritize alternative proposals for reforming the  clearance processes. Further, the omission of long-term funding  requirements limits the ability of decision makers in the executive branch  to carry out their budgetary development and oversight functions and  limits Congress’s ability to oversee the reform process and fully assess  appropriation requests. This is especially critical given the long-term fiscal  constraints that the nation faces. In particular, federal agencies may be  faced with tough future budgetary trade-offs for competing demands for  resources within the department.
section_title: Conclusions
paragraphs: The ongoing governmentwide security clearance reform effort involves the  transformation and integration of multiple processes and policies, as well  as the development of a new automated system, to make the security  clearance process more efficient and effective. Under the leadership of  OMB, the Joint Reform Team has taken several actions to improve the  security clearance process during the past year. Further, the April 2008,  December 2008, and March 2009 reform reports collectively are a step  forward. However, the Joint Reform Team will be limited in its ability to  demonstrate progress without a strategic framework that can serve as a  roadmap by identifying intended outcomes of the reform, key outcome- based performance measures with which to measure progress, and any  costs associated with the reformed process. With an outcome-based  strategic framework in place that includes two-way communication with  stakeholders, the degree of ultimate success of the reform effort depends  on the extent to which the Joint Reform Team is able to fully address,  among other things, ensuring the numbers and levels of investigations  reflect agencies’ missions, achieving reciprocity, identifying funding  requirements, developing and implementing an information technology  strategy, and making other much-needed improvements to the clearance  process as the reforms move forward. The security clearance reform  process has already been underway for several years, and various agencies  involved have created and revised several plans for improvement.  Although the high-level leadership and governance structure of the current  reform effort distinguish it from previous efforts, without a strategic  framework that fully addresses the long-standing security clearance  problems and incorporates key practices for transformation—including  the ability to demonstrate progress leading to desired results—the effort is  at risk of losing momentum and not being fully implemented.
section_title: Recommendation for Executive Action
paragraphs: To further align the reform effort with key practices for organizational  transformations and better address the long-standing problems, we  recommend that the OMB Deputy Director of Management in the capacity  as Chair of the Performance Accountability Council, ensure that the  appropriate entities—such as the Performance Accountability Council, its  subcommittees, or the Joint Reform Team—take the following action:  Establish a strategic framework for the joint reform effort to include    a mission and strategic goals;    outcome-focused performance measures to continually evaluate the  progress of the reform effort toward meeting its goals and addressing long- standing problems with the security clearance process;    a formal, comprehensive communication strategy that includes  consistency of message and encourages two-way communication between  the Performance Accountability Council and key stakeholders;    clear roles and responsibilities for the implementation of the information  technology strategy, for example, by establishing memorandums of  understanding delineating the roles and responsibilities of all agencies  responsible for developing and implementing components of the  information technology strategy; and  long-term funding requirements for security clearance reform, including  estimates of potential cost savings from the reformed process, to be  provided to decision makers in Congress and the executive branch.
section_title: Agency Comments and Our Evaluation
paragraphs: In oral comments on a draft of this report, OMB stated that it partially  concurred with our recommendation to establish a strategic framework  for the joint reform effort and that the views contained in written agency  comments on our draft report provided to us jointly by DOD and ODNI  were in alignment with those of OMB. In those written comments, DOD  and ODNI also partially concurred with our recommendation to establish a  strategic framework for the joint reform effort. While DOD and ODNI  stated that many observations in our report provided a fair assessment of  the current state of clearance reform, they also stated that our review  appears to draw overly broad conclusions from limited evidence and  noted their view that our report did not take into account that some  important components of reform remain in different stages of  development and will therefore follow a phased implementation plan. To  address our objectives during the course of our review, we collected and  analyzed reports and documents related to the reform effort produced by  the Joint Reform Team and the Performance Accountability Council, and  conducted interviews with relevant officials from the Joint Reform Team,  Performance Accountability Council, and other agencies in the federal  government involved in the reform effort. We than compared our analysis  of the reform effort to GAO’s previously issued key practices for  organizational transformations. We agree that components of the reform  are in different stages of development and in places specifically  characterized efforts as being in their initial stages. The combined DOD  and ODNI official comments are reprinted in appendix II. Additionally,  DOD and ODNI commented on the specific elements of the strategic  framework that we included as part of our recommendation.
Mission and strategic goals: DOD and ODNI stated that we had faulted  the reform effort for failing to define its mission or strategic goals in the  April and December 2008 reports and that we had implied that the effort  had none. They added that their July 2007 Terms of Reference—a  memorandum from the Director of National Intelligence to the Under  Secretary of Defense for Intelligence and the Deputy Director of National  Intelligence for Policy, Plans, and Requirements—articulated the aims of  the reform effort. These aims were to achieve comprehensive reform of  the end-to-end security clearance process delivering high-assurance  security clearances fairly, efficiently, and at the lowest reasonable cost to  the federal government. DOD and ODNI also stated that the reform effort  aims were reiterated and supported by additional detail in the April and  December 2008 reports. While this statement could serve to communicate  the reform effort’s strategic goals, we continue to note that the reform  team has not communicated strategic goals in its publicly issued joint  reform reports that collectively communicate the reform plans. Further, as  we discussed in our report, members of the Joint Reform Team and others  involved in the reform effort did not consistently identify the same goals of  the reform effort. Accordingly, we believe that the mission and strategic  goals of the reform effort should be clearly identified and stated as part of  the strategic framework as the reform effort moves forward.
Outcome-focused performance measures: In their comments, DOD and  ODNI agreed that the reform effort must contain outcome-focused  performance measures, but added that these metrics must evolve as the  process improvements and new capabilities are developed and  implemented because the effort is iterative and in phased development.  They also stated that our report claims a lack of metrics to assess the  progress of the reform effort, and disagreed with us that it will be difficult  to measure whether the reform effort is making progress, stating that the  December 2008 report details key milestones and an implementation  timeline that the Performance Accountability Council will oversee to  monitor and drive progress. While we are encouraged that DOD and ODNI  agree that outcome-focused performance measures are needed, we  continue to believe that these metrics should be identified now. We  acknowledge that the reform effort is iterative and that the reform team  has developed timelines for implementation. We agree that timelines and  milestones are useful. However, we also continue to believe that outcome- focused performance measures are a critical tool that in addition to  timelines can be used to guide the reform effort and allow overseers to  determine when the reform effort has accomplished it goals and purpose.  Further, performance measures can help the leaders assess if the effort is  getting off track or not moving toward accomplishing its goals so that the  leaders can take corrective actions, which is important during an iterative  or phased development effort such as the reform effort.
Comprehensive communication strategy: In response to our finding that  the reform effort lacks a formal, comprehensive communication strategy,  DOD and ODNI agreed with us that communication is essential. They  acknowledged that the reform effort has not had a formal, written  communication strategy, but added that the leadership of the reform effort  has aggressively pursued strategic communication opportunities at each  phase of the reform effort and continues to do so. They encouraged us to  give full consideration to extensive and repeated efforts undertaken by  several individuals involved in the process. We do state in our report that  leaders of the reform team have made multiple efforts to communicate  with stakeholders about the reform effort. Furthermore, we also agree  with DOD and ODNI statements in their agency comments that  stakeholders may be resistant to change. During our interviews with  agency officials we heard some of that resistance voiced. Therefore, we  continue to believe it is essential that the Joint Reform Team develop a  formal communication strategy to ensure that information is consistently  and accurately provided to stakeholders, including federal agencies  governmentwide that will be implementing the reformed process.  Information technology implementation roles and responsibilities: DOD  and ODNI stated that information technology has always been used in the  clearance process, and that the reform effort’s approach to improving the  use of information technology is to leverage existing systems and  capabilities, where applicable, and develop new tools where necessary.  We agree and state that the Joint Reform Team is currently working with  individual agencies to assess their information technology capabilities, and  that the reform team is in the process of weighing options for the  architecture of the future automated system that it is planning to  implement during 2009 and 2010. DOD and ODNI agreed with our report  that clearly defined roles and responsibilities are key to the success of  cross-agency information technology initiatives. They asserted that  considerable work has already been done, but added that even clearer  roles and responsibilities will be identified moving forward. Regarding our  finding that at present no single database exists in accordance with IRTPA  that requires OPM to establish an integrated database that tracks  investigations and adjudication information, DOD and ODNI stated that  the reform effort continues its iterative implementation of improvements  to systems that improve access to information that agencies need.
Long-term funding requirements: Regarding our finding that key reform  reports do not contain long-term funding requirements, DOD and ODNI  concurred that there is much more work to be done in this area, and stated  their intention to plan for and address additional funding requirements, as  required.
DOD and ODNI also provided technical comments, which we have  incorporated in the report as appropriate.
In addition, OPM provided written comments on a draft of this report,  which are reprinted in appendix III, and technical comments, which we  have incorporated in the report as appropriate. As part of its written  comments, OPM stated that it met the timeliness goals of security  clearance investigations set by IRTPA. Although timeliness was not the  focus of this review, we acknowledge this in our report. OPM also noted  that the suitability and security process should be aligned where  appropriate, and stated that the governance structure established by  Executive Order 13467 and the reform initiatives discussed in this report  are under review by the new administration. OPM, therefore, concluded  that while our findings and recommendations merit consideration, it  would not be productive to address the concerns about the “past  management of the reform process.”
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the Director  of the Office of Management and Budget, the Secretary of Defense, the  Director of the Office of the Director of National Intelligence, and the  Director of the Office of Personnel Management. In addition, the report  will be available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions on the information discussed in this  report, please contact me at (202) 512-3604 or farrellb@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this report. GAO staff who made key  contributions to this report are listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: The scope of our work included governmentwide reform efforts that were  initiated by the Joint Reform Team. These reform efforts will affect the  suitability and security clearance investigation and adjudication decisions  of all federal employees, including military servicemembers and federal  contractors from private industry.
subsections: section_title: Methodology
paragraphs: To determine the extent to which efforts to reform the personnel security  clearance process are consistent with key practices that GAO has  identified for organizational transformations, we collected and analyzed  reports and documents related to the reform effort produced by the Joint  Reform Team and the Performance Accountability Council. Specifically  we reviewed documents regarding the structure of the Performance  Accountability Council, including the charter and membership  documentation. We reviewed key legislation and executive policies,  including the Intelligence Reform and Terrorist Prevention Act of 2004 and  Executive Order 13467. Additionally, we reviewed key reports on the  reform effort such as the Joint Reform Team’s April and December 2008  progress reports and its March 2009 Enterprise Information Technology  Strategy report. Together, these documents communicate the reform plans  developed since the establishment of the Joint Reform Team in 2007. In  addition to the document analysis, we conducted interviews with relevant  officials from the Performance Accountability Council, Joint Reform  Team, and other federal agencies involved in the reform effort, such as the  Departments of Homeland Security, Veterans Affairs, Treasury, and  Energy. On the Joint Reform Team and the Performance Accountability  Council, we interviewed individuals from all four of the agencies leading  the reform effort, including DNI, OPM, OMB, and DOD and we also  interviewed officials from the team’s three areas of policy, process  improvement, and information technology. We also compared GAO’s  previously issued key practices to our analysis of the reform efforts,  including documentary and testimonial evidence, to determine the extent  to which those practices are being incorporated into the reform efforts.
To determine the extent to which the Joint Reform Team’s key security  clearance reports address factors essential to reforming the security  clearance process, we collected and analyzed reports and documents  related to the reform effort produced by the Joint Reform Team and the  Performance Accountability Council. Specifically we reviewed documents  regarding the structure of the Performance Accountability Council,  including the charter and membership documentation. We reviewed key  legislation and executive policies, including the Intelligence Reform and  Terrorist Prevention Act of 2004 and Executive Order 13467. Additionally,  we reviewed key reports on the reform effort such as the Joint Reform  Team’s April and December 2008 progress reports and its March 2009  information technology strategy report. Together, these documents  communicate the reform plans developed since the establishment of the  Joint Reform Team in 2007. In addition to the document analysis, we  conducted interviews with relevant officials from the Performance  Accountability Council, Joint Reform Team, and other federal agencies  involved in the reform effort, such as the Departments of Homeland  Security, Veterans Affairs, Treasury, and Energy. On the Joint Reform  Team and the Performance Accountability Council, we interviewed  individuals from all four of the agencies leading the reform effort,  including DNI, OPM, OMB, and DOD and we also interviewed officials  from the team’s three areas of policy, process improvement, and  information technology. Finally, we interviewed officials from DOD’s  Personnel Security Research Center. We then developed a list of factors  critical to reforming the security clearance process by leveraging the  factors we previously identified and two additional criteria that we  derived from IRTPA. We compared our analysis of the key reform reports  and testimonial information collected to the problems essential to  reforming the clearance process that we identified.
We conducted this performance audit from August 2008 through May 2009  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Department of Defense and the Director of National Intelligence
section_title: Appendix III: Comments from the Office of Personnel Management
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Acknowledgments
paragraphs: In addition to the contact named above, David Moser (Assistant Director),  Lori Atkinson, David M. Adams, Sara Cradic, Susan Ditto, Cindy Gilbert,  Greg Marchand, Shannin O’Neill, and Sarah Veale made key contributions  to this report.
section_title: Related GAO Products
paragraphs: DOD Personnel Clearances: Comprehensive Timeliness Reporting,  Complete Clearance Documentation, and Quality Measures Are Needed  to Further Improve the Clearance Process. GAO-09-400. Washington, D.C.:  May 19, 2009.
High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January  2009.
DOD Personnel Clearances: Preliminary Observations about Timeliness  and Quality. GAO-09-261R. Washington, D.C.: December 19, 2008.
Personnel Security Clearance: Preliminary Observations on Joint  Reform Efforts to Improve the Governmentwide Clearance Eligibility  Process. GAO-08-1050T. Washington, D.C.: July 30, 2008.
Personnel Clearances: Key Factors for Reforming the Security Clearance  Process. GAO-08-776T. Washington, D.C.: May 22, 2008.
Employee Security: Implementation of Identification Cards and DOD’s  Personnel Security Clearance Program Need Improvement. GAO-08-551T.  Washington, D.C.: April 9, 2008.
Personnel Clearances: Key Factors to Consider in Efforts to Reform  Security Clearance Processes. GAO-08-352T. Washington, D.C.:         February 27, 2008.
DOD Personnel Clearances: Improved Annual Reporting Would Enable  More Informed Congressional Oversight. GAO-08-350. Washington, D.C.:  February 13, 2008.
DOD Personnel Clearances: Delays and Inadequate Documentation  Found For Industry Personnel. GAO-07-842T. Washington, D.C.: May 17,  2007.
DOD Personnel Clearances: Additional OMB Actions Are Needed to  Improve the Security Clearance Process. GAO-06-1070. Washington, D.C.:  September 28, 2006.
DOD Personnel Clearances: Questions and Answers for the Record  Following the Second in a Series of Hearings on Fixing the Security  Clearance Process. GAO-06-693R. Washington, D.C.: June 14, 2006.
DOD Personnel Clearances: New Concerns Slow Processing of Clearances  for Industry Personnel. GAO-06-748T. Washington, D.C.: May 17, 2006.
DOD Personnel Clearances: Funding Challenges and Other Impediments  Slow Clearances for Industry Personnel. GAO-06-747T. Washington, D.C.:  May 17, 2006.
DOD Personnel Clearances: Government Plan Addresses Some Long- standing Problems with DOD’s Program, But Concerns Remain.  GAO-06-233T. Washington, D.C.: November 9, 2005.
Industrial Security: DOD Cannot Ensure Its Oversight of Contractors  under Foreign Influence Is Sufficient. GAO-05-681. Washington, D.C.:   July 15, 2005.