Personnel Security Clearances: Full Development and Implementation of Metrics Needed to Measure Quality of Process
Published: 2013-10-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: A high-quality personnel security clearance process is necessary to minimize the associated risks of unauthorized disclosures of classified information and to help ensure that information about individuals with criminal activity or other questionable behavior is identified and assessed as part of the process for granting or retaining clearances. Personnel security clearances allow individuals access to classified information that, through unauthorized disclosure, can in some cases cause exceptionally grave damage to U.S. national security. In 2012, the DNI reported that more than 4.9 million federal government and contractor employees held or were eligible to hold a security clearance. GAO has reported that the federal government spent over $1 billion to conduct background investigations (in support of security clearances and suitability determinations--the consideration of character and conduct for federal employment) in fiscal year 2011.
This testimony addresses the (1) overall security clearance process, including roles and responsibilities; and (2) extent that executive branch agencies have metrics to help determine the quality of the security clearance process. This testimony is based on GAO work issued between 2008 and 2013 on DOD's personnel security clearance program and governmentwide suitability and security clearance reform efforts. As part of that work, GAO (1) reviewed statutes, federal guidance, and processes, (2) examined agency data on the timeliness and quality of investigations and adjudications, (3) assessed reform efforts, and (4) reviewed samples of case files for DOD personnel.
section_title: What GAO Found
paragraphs: Multiple executive branch agencies are responsible for different steps of the multi-phased personnel security clearance process that includes: determination of whether a position requires a clearance, application submission, investigation, and adjudication. Agency officials must first determine whether a federal civilian position requires access to classified information. The Director of National Intelligence (DNI) and the Office of Personnel Management (OPM) are in the process of issuing a joint revision to the regulations guiding this step in response to GAO's 2012 recommendation that the DNI issue policy and guidance for the determination, review, and validation of requirements. After an individual has been selected for a federal civilian position that requires a personnel security clearance and the individual submits an application for a clearance, investigators--often contractors--from OPM conduct background investigations for most executive branch agencies. Adjudicators from requesting agencies use the information from these investigations and consider federal adjudicative guidelines to determine whether an applicant is eligible for a clearance. Further, individuals are subject to reinvestigations at intervals that are dependent on the level of security clearance. For example, top secret and secret clearance holders are to be reinvestigated every 5 years and 10 years, respectively.
Executive branch agencies have not fully developed and implemented metrics to measure quality throughout the personnel security clearance process. For more than a decade, GAO has emphasized the need to build and monitor quality throughout the personnel security clearance process to promote oversight and positive outcomes such as maximizing the likelihood that individuals who are security risks will be scrutinized more closely. For example, GAO reported in May 2009 that, with respect to initial top secret clearances adjudicated in July 2008 for the Department of Defense (DOD), documentation was incomplete for most of OPM's investigative reports. GAO independently estimated that 87 percent of about 3,500 investigative reports that DOD adjudicators used to make clearance eligibility decisions were missing some required documentation, such as the verification of all of the applicant's employment. GAO also estimated that 12 percent of the 3,500 reports did not contain the required personal subject interview. In 2009, GAO recommended that OPM measure the frequency with which its investigative reports met federal investigative standards in order to improve the quality of investigation documentation. As of August 2013, however, OPM had not implemented this recommendation. GAO's 2009 report also identified issues with the quality of DOD adjudications. Specifically, GAO estimated that 22 percent of about 3,500 initial top secret clearances that were adjudicated favorably did not contain all the required documentation. As a result, in 2009 GAO recommended that DOD measure the frequency with which adjudicative files meet requirements. In November 2009, DOD issued a memorandum that established a tool called the Review of Adjudication Documentation Accuracy and Rationales (RADAR) to measure the frequency with which adjudicative files meet the requirements of DOD regulation. According to a DOD official, RADAR had been used in fiscal year 2010 to evaluate some adjudications, but was not used in fiscal year 2011 due to funding shortfalls. DOD restarted the use of RADAR in fiscal year 2012.

section_title: Letter
paragraphs: Thank you for the opportunity to be here to participate in this discussion  of the federal government’s process for personnel security clearances. A  high-quality personnel security clearance process is necessary to  minimize the associated risks of unauthorized disclosures of classified  information and to help ensure that information about individuals with  criminal activity or other questionable behavior is identified and assessed  as part of the process for granting or retaining clearances. However,  recent events, such as unauthorized disclosures of classified information,  have shown that there is more work to be done by federal agencies to  help ensure the process functions effectively and efficiently, so that only  trustworthy individuals obtain and keep security clearances and the  resulting access to classified information that clearances make possible.
As you know, we have an extensive body of work on issues related to the  personnel security clearance process going back over a decade. Since  2008, we have focused on the government-wide effort to reform the  security clearance process. Personnel security clearances allow  government and industry personnel (contractors) to gain access to  classified information that, through unauthorized disclosure, can in some  cases cause exceptionally grave damage to U.S. national security. It is  important to keep in mind that security clearances allow for access to  classified information on a need to know basis. Federal agencies also use  other processes and procedures to determine if an individual should be  granted access to certain government buildings or facilities or be  employed as either a military, federal civilian employee, or contractor for  the federal government. Separate from, but related to, personnel security  clearances are determinations of suitability that the executive branch  uses to ensure individuals are suitable, based on character and conduct,  for federal employment in their agency or position.
The federal government processes a high volume of personnel security  clearances at significant costs. In 2012, the Director of National  Intelligence (DNI) reported that more than 4.9 million federal government  and contractor employees held or were eligible to hold a security  clearance, which poses a formidable challenge to those responsible for  deciding who should be granted a clearance. Furthermore, the federal  government spent over $1 billion to conduct more than 2 million  background investigations (in support of both personnel security  clearances and suitability determinations for government employment  outside of the intelligence community) in fiscal year 2011. The  Department of Defense (DOD) accounts for the majority of all personnel  security clearances—which includes 788,000 background investigations  that cost over $787 million in fiscal year 2011.
My testimony today will focus on two topics related to personnel security  clearances. First, I will discuss the overall personnel security clearance  process, including roles and responsibilities for investigations and  adjudications. Second, I will discuss the extent that executive branch  agencies have developed and implemented metrics to help determine the  quality of the security clearance process.
My testimony is based on our reports and testimonies issued from 2008  through 2013 on DOD’s personnel security clearance program and  government-wide suitability and security clearance reform efforts. A list of  these related products appears at the end of my statement. As part of the  work for these products, we reviewed statutes, federal guidance and  processes, examined agency data on the timeliness and quality of  investigations and adjudications, assessed reform efforts, and reviewed a  sample of investigative and adjudication files for DOD personnel. The  work upon which this testimony is based was conducted in accordance  with generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on our audit objectives. We believe that the evidence obtained  provides a reasonable basis for our findings and conclusions based on  our audit objectives. Further details about the scope and methodology  can be found in each of these related products.
subsections: section_title: The Overall Personnel Security Clearance Process
paragraphs: Multiple executive-branch agencies have key roles and responsibilities for  different steps of the federal government’s personnel security clearance  process. For example, in 2008, Executive Order 13467 designated the  DNI as the Security Executive Agent. As such, the DNI is responsible for  developing policies and procedures to help ensure the effective, efficient,  and timely completion of background investigations and adjudications  relating to determinations of eligibility for access to classified information  and eligibility to hold a sensitive position. In turn, executive branch  agencies determine which of their positions—military, civilian, or private- industry contractors—require access to classified information and,  therefore, which people must apply for and undergo a personnel security  clearance investigation. Investigators—often contractors—from Federal  Investigative Services within the Office of Personnel Management (OPM)  conduct these investigations for most of the federal government using  federal investigative standards and OPM internal guidance as criteria for  collecting background information on applicants. OPM provides the  resulting investigative reports to the requesting agencies for their internal  adjudicators, who use the information along with the federal adjudicative  guidelines to determine whether an applicant is eligible for a personnel  security clearance. DOD is OPM’s largest customer, and its Under  Secretary of Defense for Intelligence (USD(I)) is responsible for  developing, coordinating, and overseeing the implementation of DOD  policy, programs, and guidance for personnel, physical, industrial,  information, operations, chemical/biological, and DOD Special Access  Program security. Additionally, the Defense Security Service, under the  authority, direction, and control of USD(I), manages and administers the  DOD portion of the National Industrial Security Program for the DOD  components and other federal agencies by agreement, as well as  providing security education and training, among other things.
Section 3001 of the Intelligence Reform and Terrorism Prevention Act of  2004 prompted government-wide suitability and security clearance  reform. The act required, among other matters, an annual report to  Congress—in February of each year from 2006 through 2011—about  progress and key measurements on the timeliness of granting security  clearances. It specifically required those reports to include the periods of  time required for conducting investigations and adjudicating or granting  clearances. However, the Intelligence Reform and Terrorism Prevention  Act requirement for the executive branch to annually report on its  timeliness expired in 2011. More recently the Intelligence Authorization  Act of 2010 established a new requirement that the President annually  report to Congress the total amount of time required to process certain  security clearance determinations for the previous fiscal year for each  element of the Intelligence Community. The Intelligence Authorization  Act of 2010 additionally requires that those annual reports include the  total number of active security clearances throughout the United States  government, to include both government employees and contractors.  Unlike the Intelligence Reform and Terrorism Prevention Act of 2004  reporting requirement, the requirement to submit these annual reports  does not expire.
In 2007, DOD and the Office of the Director of National Intelligence  (ODNI) formed the Joint Security Clearance Process Reform Team,  known as the Joint Reform Team, to improve the security clearance  process government-wide. In a 2008 memorandum, the President called  for a reform of the security clearance and suitability determination  processes and subsequently issued Executive Order 13467, which in  addition to designating the DNI as the Security Executive Agent, also  designated the Director of OPM as the Suitability Executive Agent.  Specifically, the Director of OPM, as Suitability Executive Agent, is  responsible for developing policies and procedures to help ensure the  effective, efficient, and timely completion of investigations and  adjudications relating to determinations of suitability, to include  consideration of an individual’s character or conduct. Further, the  executive order established a Suitability and Security Clearance  Performance Accountability Council to oversee agency progress in  implementing the reform vision. Under the executive order, this council is  accountable to the President for driving implementation of the reform  effort, including ensuring the alignment of security and suitability  processes, holding agencies accountable for implementation, and  establishing goals and metrics for progress. The order also appointed the  Deputy Director for Management at the Office of Management and  Budget as the chair of the council.
subsections: section_title: Steps in the Personnel Security Clearance Process
paragraphs: In the first step of the personnel security clearance process, executive  branch officials determine the requirements of a federal civilian position,  including assessing the risk and sensitivity level associated with that  position, to determine whether it requires access to classified information  and, if required, the level of access. Security clearances are generally  categorized into three levels: top secret, secret, and confidential. The  level of classification denotes the degree of protection required for  information and the amount of damage that unauthorized disclosure could  reasonably be expected to cause to national defense or foreign relations.  A sound requirements process is important because requests for  clearances for positions that do not need a clearance or need a lower  level of clearance increase investigative workloads and costs. In 2012, we  reported that the DNI, as the Security Executive Agent, had not provided  agencies clearly defined policy and procedures to consistently determine  if a position requires a security clearance, or established guidance to  require agencies to review and revise or validate existing federal civilian  position designations. We recommended that the DNI issue policy and  guidance for the determination, review, and validation of requirements,  and ODNI concurred with those recommendations, stating that it  recognized the need to issue or clarify policy. Currently, OPM and ODNI  are in the process of issuing a joint revision to the regulations guiding  requirements determination. Specifically, according to officials from the  ODNI, these offices had obtained permission from the President to re- issue the federal regulation jointly, drafted the proposed rule, and  obtained public input on the regulation by publishing it in the Federal  Register. According to ODNI and OPM officials, they will jointly review  and address comments and prepare the final rule for approval from the  Office of Management and Budget.
Once an applicant is selected for a position that requires a personnel  security clearance, the applicant must obtain a security clearance in order  to gain access to classified information. While different departments and  agencies may have slightly different personnel security clearance  processes, the phases that follow—application submission, investigation,  and adjudication—are illustrative of a typical process. Since 1997,  federal agencies have followed a common set of personnel security  investigative standards and adjudicative guidelines for determining  whether federal civilian workers, military personnel, and others, such as  private industry personnel contracted by the government, are eligible to  hold a security clearance. Figure 1 illustrates the steps in the personnel  security clearance process, which is representative of the general  process followed by most executive branch agencies and includes  procedures for appeals and renewals.
During the application submission phase, a security officer from an  executive branch agency (1) requests an investigation of an individual  requiring a clearance; (2) forwards a personnel security questionnaire  (Standard Form 86) using OPM’s electronic Questionnaires for  Investigations Processing (e-QIP) system or a paper copy of the Standard  Form 86 to the individual to complete; (3) reviews the completed  questionnaire; and (4) sends the questionnaire and supporting  documentation, such as fingerprints and signed waivers, to OPM or its  investigation service provider.
During the investigation phase, investigators—often contractors—from  OPM’s Federal Investigative Services use federal investigative standards  and OPM’s internal guidance to conduct and document the investigation  of the applicant. The scope of information gathered in an investigation  depends on the needs of the client agency and the personnel security  clearance requirements of an applicant’s position, as well as whether the  investigation is for an initial clearance or a reinvestigation to renew a  clearance. For example, in an investigation for a top secret clearance,  investigators gather additional information through more time-consuming  efforts, such as traveling to conduct in-person interviews to corroborate  information about an applicant’s employment and education. However,  many background investigation types have similar components. For  instance, for all investigations, information that applicants provide on  electronic applications are checked against numerous databases. Both  secret and top secret investigations contain credit and criminal history  checks, while top secret investigations also contain citizenship, public  record, and spouse checks as well as reference interviews and an  Enhanced Subject Interview to gain insight into an applicant’s character.  Table 1 highlights the investigative components generally associated with  the secret and top secret clearance levels. After OPM, or the designated  provider, completes the background investigation, the resulting  investigative report is provided to the adjudicating agency.
During the adjudication phase, adjudicators from the hiring agency use  the information from the investigative report to determine whether an  applicant is eligible for a security clearance. To make clearance eligibility  decisions, the adjudication guidelines specify that adjudicators consider  13 specific areas that elicit information about (1) conduct that could raise  security concerns and (2) factors that could allay those security concerns  and permit granting a clearance. If a clearance is denied or revoked,  appeals of the adjudication decision are possible. We have work  underway to review the process for security revocations. We expect to  issue a report on this process by spring of 2014.
Once an individual has obtained a personnel security clearance and as  long as they remain in a position that requires access to classified  national security information, that individual is reinvestigated periodically  at intervals that are dependent on the level of security clearance. For  example, top secret clearance holders are reinvestigated every 5 years,  and secret clearance holders are reinvestigated every 10 years. Some of  the information gathered during a reinvestigation would focus specifically  on the period of time since the last approved clearance, such as a check  of local law enforcement agencies where an individual lived and worked  since the last investigation. Further, the Joint Reform Team began an  effort to review the possibility of continuous evaluations, which would  ascertain on a more frequent basis whether an eligible employee with  access to classified information continues to meet the requirements for  access. Specifically, the team proposed to move from periodic review to  that of continuous evaluation, meaning annually for top secret and similar  positions and at least once every five years for secret or similar positions,  as a means to reveal security-relevant information earlier than the  previous method, and provide increased scrutiny on populations that  could potentially represent risk to the government because they already  have access to classified information. The current federal investigative  standards state that the top secret level of security clearances may be  subject to continuous evaluation.
section_title: Full Development and Implementation of Metrics Needed to Determine Quality of Personnel Security Clearance Process
paragraphs: The executive branch has developed some metrics to assess quality at  different phases of the personnel security clearance process; however,  those metrics have not been fully developed and implemented. To  promote oversight and positive outcomes, such as maximizing the  likelihood that individuals who are security risks will be scrutinized more  closely, we have emphasized, since the late 1990s, the need to build  and monitor quality throughout the personnel security clearance process.  Having assessment tools and performance metrics in place is a critical  initial step toward instituting a program to monitor and independently  validate the effectiveness and sustainability of corrective measures.  However, we have previously reported that executive branch agencies  have not fully developed and implemented metrics to measure quality in  key aspects of the personnel security clearance process, including: (1)  investigative reports; (2) adjudicative files; and (3) the reciprocity of  personnel security clearances, which is an agency’s acceptance of a  background investigation or clearance determination completed by any  authorized investigative or adjudicative executive branch agency.
subsections: section_title: Metrics Not Yet Implemented to Measure Completeness of OPM Investigative Reports
paragraphs: We have previously identified deficiencies in OPM’s investigative  reports—results from background investigations—but as of August 2013  OPM had not yet implemented metrics to measure the completeness of  these reports. OPM supplies about 90 percent of all federal clearance  investigations, including those for DOD. For example, in May 2009 we  reported that, with respect to DOD initial top secret clearances  adjudicated in July 2008, documentation was incomplete for most OPM  investigative reports. We independently estimated that 87 percent of  about 3,500 investigative reports that DOD adjudicators used to make  clearance decisions were missing at least one type of documentation  required by federal investigative standards. The type of documentation  most often missing from investigative reports was verification of all of the  applicant’s employment, followed by information from the required  number of social references for the applicant and complete security  forms. We also estimated that 12 percent of the 3,500 investigative  reports did not contain a required personal subject interview.
At the time of our 2009 review, OPM did not measure the completeness  of its investigative reports, which limited the agency’s ability to explain the  extent or the reasons why some reports were incomplete. As a result of  the incompleteness of OPM’s investigative reports on DOD personnel, we  recommended in May 2009 that OPM measure the frequency with which  its investigative reports meet federal investigative standards, so that the  executive branch can identify the factors leading to incomplete reports  and take corrective actions.
In a subsequent February 2011 report, we noted that OMB, ODNI, DOD,  and OPM leaders had provided congressional members with metrics to  assess the quality of the security clearance process, including  investigative reports and other aspects of the process. For example, the  Rapid Assessment of Incomplete Security Evaluations was one tool the  executive branch agencies planned to use for measuring quality, or  completeness, of OPM’s background investigations. However,  according to an OPM official in June 2012, OPM chose not to use this  tool. Instead, OPM opted to develop another tool. In following up on our  2009 recommendations, as of August 2013, OPM had not provided  enough details on its tool for us to determine if the tool had met the intent  of our 2009 recommendation, and included the attributes of successful  performance measures identified in best practices, nor could we  determine the extent to which the tool was being used.
OPM also assesses the quality of investigations based on voluntary  reporting from customer agencies. Specifically, OPM tracks investigations  that are (1) returned for rework from the requesting agency, (2) identified  as deficient using a web-based customer satisfaction survey, or (3)  identified as deficient through adjudicator calls to OPM’s quality hotline.  However, in our past work, we have noted that the number of  investigations returned for rework is not by itself a valid indicator of the  quality of investigative work because DOD adjudication officials told us  that they have been reluctant to return incomplete investigations in  anticipation of delays that would impact timeliness. Further, relying on  agencies to voluntarily provide information on investigation quality may  not reflect the quality of OPM’s total investigation workload. We are  beginning work to further review OPM’s actions to improve the quality of  investigations.
We have also reported that deficiencies in investigative reports affect the  quality of the adjudicative process. Specifically, in November 2010, we  reported that agency officials who utilize OPM as their investigative  service provider cited challenges related to deficient investigative reports  as a factor that slows agencies’ abilities to make adjudicative decisions.  The quality and completeness of investigative reports directly affects  adjudicator workloads, including whether additional steps are required  before adjudications can be made, as well as agency costs. For example,  some agency officials noted that OPM investigative reports do not include  complete copies of associated police reports and criminal record checks.  Several agency officials stated that in order to avoid further costs or  delays that would result from working with OPM, they often choose to  perform additional steps internally to obtain missing information.  According to ODNI and OPM officials, OPM investigators provide a  summary of police and criminal reports and assert that there is no policy  requiring inclusion of copies of the original records. However, ODNI  officials also stated that adjudicators may want or need entire records as  critical elements may be left out. For example, according to Defense  Office of Hearings and Appeals officials, in one case, an investigator’s  summary of a police report incorrectly identified the subject as a thief  when the subject was actually the victim.
section_title: DOD Has Taken Steps to Implement Measures to Determine Completeness of Adjudicative Files
paragraphs: DOD has taken some intermittent steps to implement measures to  determine the completeness of adjudicative files to address issues  identified in our 2009 report regarding the quality of DOD adjudications. In  2009, we found that some clearances were granted by DOD adjudicators  even though some required data were missing from the OPM  investigative reports used to make such determinations. For example, we  estimated in our 2009 review that 22 percent of the adjudicative files for  about 3,500 initial top secret clearances that were adjudicated favorably  did not contain all the required documentation, even though DOD  regulations require that adjudicators maintain a record of each favorable  and unfavorable adjudication decision and document the rationale for  granting clearance eligibility to applicants with security concerns revealed  during the investigation. Documentation most frequently missing from  adjudicative files was the rationale for granting security clearances to  applicants with security concerns related to foreign influence, financial  considerations, and criminal conduct. At the time of our 2009 review,  DOD did not measure the completeness of its adjudicative files, which  limited the agency’s ability to explain the extent or the reasons why some  files are incomplete.
In 2009, we made two recommendations to improve the quality of  adjudicative files. First, we recommended that DOD measure the  frequency with which adjudicative files meet requirements, so that the  executive branch can identify the factors leading to incomplete files and  include the results of such measurement in annual reports to Congress  on clearances. In November 2009, DOD subsequently issued a  memorandum that established a tool to measure the frequency with which  adjudicative files meet the requirements of DOD regulation. Specifically,  the DOD memorandum stated that it would use a tool called the Review  of Adjudication Documentation Accuracy and Rationales, or RADAR, to  gather specific information about adjudication processes at the  adjudication facilities and assess the quality of adjudicative  documentation. In following up on our 2009 recommendations, as of  2012, a DOD official stated that RADAR had been used in fiscal year  2010 to evaluate some adjudications, but was not used in fiscal year 2011  due to funding shortfalls. DOD restarted the use of RADAR in fiscal year  2012.
Second, we recommended that DOD issue guidance to clarify when  adjudicators may use incomplete investigative reports as the basis for  granting clearances. In response to our recommendation, DOD’s  November 2009 guidance that established RADAR also outlines the  minimum documentation requirements adjudicators must adhere to when  documenting personnel security clearance determinations for cases with  potentially damaging information. In addition, DOD issued guidance in  March 2010 that clarifies when adjudicators may use incomplete  investigative reports as the basis for granting clearances. This guidance  provides standards that can be used for the sufficient explanation of  incomplete investigative reports.
section_title: Metrics Not Yet Implemented to Measure Clearance Reciprocity
paragraphs: While some efforts have been made to develop quality metrics, agencies  have not yet implemented metrics for tracking the reciprocity of personnel  security clearances, which is an agency’s acceptance of a background  investigation or clearance determination completed by any authorized  investigative or adjudicative executive branch agency. Although executive  branch agency officials have stated that reciprocity is regularly granted,  as it is an opportunity to save time as well as reduce costs and  investigative workloads, we reported in 2010 that agencies do not  consistently and comprehensively track the extent to which reciprocity is  granted government-wide. ODNI guidance requires, except in limited  circumstances, that all Intelligence Community elements “accept all in- scope security clearance or access determinations.” Additionally, Office  of Management and Budget guidance requires agencies to honor a  clearance when (1) the prior clearance was not granted on an interim or  temporary basis; (2) the prior clearance investigation is current and in- scope; (3) there is no new adverse information already in the possession  of the gaining agency; and (4) there are no conditions, deviations,  waivers, or unsatisfied additional requirements (such as polygraphs) if the  individual is being considered for access to highly sensitive programs.
While the Performance Accountability Council has identified reciprocity as  a government-wide strategic goal, we have found that agencies do not  consistently and comprehensively track when reciprocity is granted, and  lack a standard metric for tracking reciprocity. Further, while OPM and  the Performance Accountability Council have developed quality metrics  for reciprocity, the metrics do not measure the extent to which reciprocity  is being granted. For example, OPM created a metric in early 2009 to  track reciprocity, but this metric only measures the number of  investigations requested from OPM that are rejected based on the  existence of a previous investigation and does not track the number of  cases in which an existing security clearance was or was not successfully  honored by the agency. Without comprehensive, standardized metrics to  track reciprocity and consistent documentation of the findings, decision  makers will not have a complete picture of the extent to which reciprocity  is granted or the challenges that agencies face when attempting to honor  previously granted security clearances.
In 2010, we reported that executive branch officials routinely honor other  agencies’ security clearances, and personnel security clearance  information is shared between OPM, DOD, and, to some extent,  Intelligence Community databases. However, we found that some  agencies find it necessary to take additional steps to address limitations  with available information on prior investigations, such as insufficient  information in the databases or variances in the scope of investigations,  before granting reciprocity. For instance, OPM has taken steps to ensure  certain clearance data necessary for reciprocity are available to  adjudicators, such as holding interagency meetings to determine new  data fields to include in shared data. However, we also found that the  shared information available to adjudicators contains summary-level  detail that may not be complete. As a result, agencies may take steps to  obtain additional information, which creates challenges to immediately  granting reciprocity.
Further, in 2010 we reported that because there is no government-wide  standardized training and certification process for investigators and  adjudicators, according to agency officials, a subject’s prior clearance  investigation and adjudication may not meet the standards of the inquiring  agency. Although OPM has developed some training, security clearance  investigators and adjudicators are not required to complete a certain type  or number of classes. As a result, the extent to which investigators and  adjudicators receive training varies by agency. Consequently, as we have  previously reported, agencies are reluctant to be accountable for  investigations and/or adjudications conducted by other agencies or  organizations. To achieve fuller reciprocity, clearance-granting agencies  seek to have confidence in the quality of prior investigations and  adjudications.
Consequently, we recommended in 2010 that the Deputy Director of  Management, Office of Management and Budget, in the capacity as Chair  of the Performance Accountability Council, should develop  comprehensive metrics to track reciprocity and then report the findings  from the expanded tracking to Congress. Although OMB agreed with our  recommendation, a 2011 ODNI report found that Intelligence Community  agencies experienced difficulty reporting on reciprocity. The agencies are  required to report on a quarterly basis the number of security clearance  determinations granted based on a prior existing clearance as well as the  number not granted when a clearance existed. The numbers of reciprocal  determinations made and denied are categorized by the individual’s  originating and receiving organizational type: (1) government to  government, (2) government to contractor, (3) contractor to government,  and (4) contractor to contractor. The report stated that data fields  necessary to collect the information described above do not currently  reside in any of the datasets available and the process was completed in  an agency specific, semi-manual method. Further, the Deputy Assistant  Director for Special Security of the Office of the Director of National  Intelligence noted in testimony in June 2012 that measuring reciprocity is  difficult, and despite an abundance of anecdotes, real data is hard to  come by. To address this problem, ODNI is developing a web-based form  for individuals to submit their experience with reciprocity issues to the  ODNI. According to ODNI, this will allow them to collect empirical data,  perform systemic trend analysis, and assist agencies with achieving  workable solutions.
section_title: Sustained Leadership Needed to Fully Develop and Implement Metrics to Monitor and Track Quality
paragraphs: As previously discussed, DOD accounts for the majority of security  clearances within the federal government. We initially placed DOD’s  personnel security clearance program on our high-risk list in 2005  because of delays in completing clearances. It remained on our list until  2011 because of ongoing concerns about delays in processing  clearances and problems with the quality of investigations and  adjudications. In February 2011, we removed DOD’s personnel security  clearance program from our high-risk list largely because of the  department’s demonstrated progress in expediting the amount of time  processing clearances. We also noted DOD’s efforts to develop and  implement tools to evaluate the quality of investigations and  adjudications.
Even with the significant progress leading to removal of DOD’s program  from our high-risk list, we noted in June 2012 that sustained leadership  would be necessary to continue to implement, monitor, and update  outcome-focused performance measures. The initial development of  some tools and metrics to monitor and track quality not only for DOD but  government-wide were positive steps; however, full implementation of  these tools and measures government-wide have not yet been realized.  While progress in DOD’s personnel security clearance program resulted  in the removal of this area from our high-risk list, significant government- wide challenges remain in ensuring that personnel security clearance  investigations and adjudications are high-quality.
In conclusion, oversight of the reform efforts to measure and improve the  quality of the security clearance process—including background  investigations—are imperative next steps. Failing to do so increases the  risk of damaging, unauthorized disclosures of classified information. The  progress that was made with respect to expediting the amount of time  processing clearances would not have been possible without committed  and sustained congressional oversight and the leadership of the  Performance Accountability Council. Further actions are needed now to  fully develop and implement metrics to oversee quality at every step in  the process. Chairman Carper, Ranking Member Coburn, this concludes  my prepared statement. I would be pleased to answer any questions that  you or other Members of the Committee may have at this time.
section_title: GAO Contacts and Acknowledgment
paragraphs: For further information on this testimony, please contact Brenda S.  Farrell, Director, Defense Capabilities and Management, who may be  reached at (202) 512-3604 or farrellb@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this statement. GAO staff who made key contributions to  this testimony include Lori Atkinson (Assistant Director), Darreisha Bates,  Renee Brown, John Van Schaik, and Michael Willems.
section_title: Related GAO Products
paragraphs: Personnel Security Clearances: Further Actions Needed to Improve the  Process and Realize Efficiencies. GAO-13-728T. Washington, D.C.: June  20, 2013.
Managing for Results: Agencies Should More Fully Develop Priority Goals  under the GPRA Modernization Act. GAO-13-174. Washington, D.C.:  April 19, 2013.
Security Clearances: Agencies Need Clearly Defined Policy for  Determining Civilian Position Requirements. GAO-12-800. Washington,  D.C.: July 12, 2012.
Personnel Security Clearances: Continuing Leadership and Attention Can  Enhance Momentum Gained from Reform Effort. GAO-12-815T.  Washington, D.C.: June 21, 2012.  2012 Annual Report: Opportunities to Reduce Duplication, Overlap and  Fragmentation, Achieve Savings, and Enhance Revenue.  GAO-12-342SP. Washington, D.C.: February 28, 2012.
Background Investigations: Office of Personnel Management Needs to  Improve Transparency of Its Pricing and Seek Cost Savings.  GAO-12-197. Washington, D.C.: February 28, 2012.
GAO’s 2011 High-Risk Series: An Update. GAO-11-394T. Washington,  D.C.: February 17, 2011.
High-Risk Series: An Update. GAO-11-278. Washington, D.C.: February  16, 2011.
Personnel Security Clearances: Overall Progress Has Been Made to  Reform the Governmentwide Security Clearance Process. GAO-11-232T.  Washington, D.C.: December 1, 2010.
Personnel Security Clearances: Progress Has Been Made to Improve  Timeliness but Continued Oversight Is Needed to Sustain Momentum.  GAO-11-65. Washington, D.C.: November 19, 2010.
DOD Personnel Clearances: Preliminary Observations on DOD’s  Progress on Addressing Timeliness and Quality Issues. GAO-11-185T.  Washington, D.C.: November 16, 2010.
Personnel Security Clearances: An Outcome-Focused Strategy and  Comprehensive Reporting of Timeliness and Quality Would Provide  Greater Visibility over the Clearance Process. GAO-10-117T.  Washington, D.C.: October 1, 2009.
Personnel Security Clearances: Progress Has Been Made to Reduce  Delays but Further Actions Are Needed to Enhance Quality and Sustain  Reform Efforts. GAO-09-684T. Washington, D.C.: September 15, 2009.
Personnel Security Clearances: An Outcome-Focused Strategy Is  Needed to Guide Implementation of the Reformed Clearance Process.  GAO-09-488. Washington, D.C.: May 19, 2009.
DOD Personnel Clearances: Comprehensive Timeliness Reporting,  Complete Clearance Documentation, and Quality Measures Are Needed  to Further Improve the Clearance Process. GAO-09-400. Washington,  D.C.: May 19, 2009.
High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January  2009.
Personnel Security Clearances: Preliminary Observations on Joint  Reform Efforts to Improve the Governmentwide Clearance Eligibility  Process. GAO-08-1050T. Washington, D.C.: July 30, 2008.
Personnel Clearances: Key Factors for Reforming the Security Clearance  Process. GAO-08-776T. Washington, D.C.: May 22, 2008.
Employee Security: Implementation of Identification Cards and DOD’s  Personnel Security Clearance Program Need Improvement.  GAO-08-551T. Washington, D.C.: April 9, 2008.
Personnel Clearances: Key Factors to Consider in Efforts to Reform  Security Clearance Processes. GAO-08-352T. Washington, D.C.:  February 27, 2008.
DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts  to Improve Clearance Processes for Industry Personnel. GAO-08-470T.  Washington, D.C.: February 13, 2008.
DOD Personnel Clearances: Improved Annual Reporting Would Enable  More Informed Congressional Oversight. GAO-08-350. Washington, D.C.:  February 13, 2008.
DOD Personnel Clearances: Delays and Inadequate Documentation  Found for Industry Personnel. GAO-07-842T. Washington, D.C.: May 17,  2007.
High-Risk Series: An Update. GAO-07-310. Washington, D.C.: January  2007.
DOD Personnel Clearances: Additional OMB Actions Are Needed to  Improve the Security Clearance Process. GAO-06-1070. Washington,  D.C.: September 28, 2006.
DOD Personnel Clearances: New Concerns Slow Processing of  Clearances for Industry Personnel. GAO-06-748T. Washington, D.C.:  May 17, 2006.
DOD Personnel Clearances: Funding Challenges and Other Impediments  Slow Clearances for Industry Personnel. GAO-06-747T. Washington,  D.C.: May 17, 2006.
DOD Personnel Clearances: Government Plan Addresses Some Long- standing Problems with DOD’s Program, But Concerns Remain.  GAO-06-233T. Washington, D.C.: November 9, 2005.
DOD Personnel Clearances: Some Progress Has Been Made but Hurdles  Remain to Overcome the Challenges That Led to GAO’s High-Risk  Designation. GAO-05-842T. Washington, D.C.: June 28, 2005.
High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January  2005.
DOD Personnel Clearances: Preliminary Observations Related to  Backlogs and Delays in Determining Security Clearance Eligibility for  Industry Personnel. GAO-04-202T. Washington, D.C.: May 6, 2004.
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