Personnel Security Clearances: Continuing Leadership and Attention Can Enhance Momentum Gained from Reform Effort
Published: 2012-06-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: As of October 2010, the Office of the Director of National Intelligence reported that 3.9 million federal employees (military and civilians) and contractors hold security clearances. DOD comprises the vast majority of government security clearances. Longstanding backlogs and delays in the security clearance process led GAO to place the DODs Personnel Security Clearance Program on its high-risk list in 2005. Delays in issuing clearances can result in millions of dollars of additional cost to the federal government and could pose a national security risk. DOD and others have taken steps to address these issues and additional concerns with clearance documentation used to determine eligibility for a clearance. As a result, in 2011, GAO removed the program from its high-risk list.
This testimony addresses (1) the key actions that led GAO to remove DODs security clearance program from its high-risk list and (2) the additional actions that can enhance the security clearance reform efforts. This statement is based on prior GAO reports and testimonies on DODs personnel security clearance program and governmentwide suitability and security clearance reform efforts.
section_title: What GAO Found
paragraphs: Since GAO first identified the Department of Defenses (DOD) Personnel Security Clearance Program as a high-risk area, DOD, in conjunction with Congress and executive agency leadership, took actions that resulted in significant progress toward improving the processing of security clearances. Congress held more than 14 oversight hearings to help oversee key legislation, such as the Intelligence Reform and Terrorism Prevention Act of 2004, which helped focus attention and sustain momentum of the governmentwide reform effort. In addition, the committed and collaborative efforts of DOD, the Office of the Director of National Intelligence (ODNI), Office of Management and Budget (OMB), and Office of Personnel Management (OPM) as leaders of the Suitability and Security Clearance Performance Accountability Council (Performance Accountability Council) demonstrated commitment to and created a vision for the reform effort, which led to significant improvements in the timeliness of processing security clearances. As a result, in 2011, GAO removed DODs Personnel Security Clearance Program from its high-risk list because of the agencys progress in improving timeliness, development of tools and metrics to assess quality, and commitment to sustaining progress. Specifically, GAO found that DOD met the 60-day statutory timeliness objective for processing initial clearances in fiscal year 2010 by processing 90 percent of its initial clearances in an average of 49 days. In addition, DOD developed two quality tools to evaluate completeness of investigation documentation and agencies' adjudication process regarding the basis for granting security clearances. Moreover, DOD, ODNI, OMB, and OPM developed and are in the process of implementing 15 metrics that assess the timeliness and quality of investigations, adjudications, reciprocity and automation of security clearances.
Even with the significant progress in recent years, sustained leadership attention to the following additional actions, on which GAO has previously reported, can enhance the security clearance reform efforts of executive branch agencies and the Performance Accountability Council:
Continue to implement, monitor, and update outcome-focused performance measures. The development of tools and metrics to monitor and track quality are positive steps, but full implementation of these tools and measures will enable the executive branch to demonstrate progress in quality improvements and contribute to greater visibility over the clearance process.
Seek opportunities to enhance efficiencies and manage costs related to the reform effort. Given the current fiscal constraints, identifying long-term funding requirements for the security clearance process is critical for the executive branch to sustain the reform effort. Further, the reform efforts are a venue to facilitate the identification of efficiencies in areas including information technology and investigation and adjudication case management processes.
Create a sound requirements process for determining which positions require clearances and level of clearances. A sound requirements determination process may help ensure that workload and costs are not higher than necessary by ensuring that clearances are only requested for positions when needed and that the appropriate clearance level is requested.

section_title: Letter
paragraphs: Thank you for the opportunity to discuss the removal of the Department of  Defense’s (DOD) personnel security clearance program from our high-risk  list. As you know, we maintain a program to focus attention on  government operations that we identify as high risk due to their greater  vulnerabilities to fraud, waste, abuse, and mismanagement or the need  for transformation to address economy, efficiency, or effectiveness  challenges. In the past two decades, the attention of Congress, the  agencies, and others to high-risk areas has brought results. Over         one-third of the areas previously designated as high-risk have been  removed from the list because significant progress was made to address  the problems. When legislative, administrative, and agency actions,  including those in response to our recommendations, result in significant  progress toward resolving a high-risk problem, we remove the high risk  designation. In 2011, DOD’s personnel security clearance program  became the first designated defense area to be removed from our high- risk list. Seven DOD high-risk areas remain on the list. My testimony  today will focus on (1) the key actions that led us to remove DOD’s  personnel security clearance program from our high-risk list, and (2)  additional actions that can enhance the governmentwide personnel  security clearance reform efforts.
Personnel security clearances allow government and industry personnel  to gain access to classified information that, through unauthorized  disclosure can in some cases cause exceptionally grave damage to     U.S. national security. The 2010 unauthorized leaks of about 500,000  classified documents posted to the Internet related to the wars in  Afghanistan and Iraq are examples of the inherent risks involved when  granting an individual a security clearance. As you know, there continues  to be a high volume of clearances processed. For example, prior to  September 11, 2001, we reported that DOD processed about 200,000  clearances annually. For fiscal year 2008, we reported that DOD  approved personnel security clearances for approximately 630,000  military, civilian, and industry personnel. In 2010, the Director of National  Intelligence reported that there were approximately 3.9 million federal  government and contractor employees who held a security clearance.
DOD accounts for the vast majority of all initial personnel security  clearances, making it a formidable challenge to those responsible for  deciding who should be granted a clearance.
Multiple executive-branch agencies are responsible for different phases in  the federal government’s personnel security clearance process. With  respect to DOD’s personnel security clearance program, DOD is  responsible for determining which military, DOD civilian, and private- industry personnel working on DOD contracts require access to classified  information and must apply for a security clearance and undergo an  investigation. The Office of Personnel Management (OPM), in turn,  conducts these investigations for DOD. OPM investigators—often  contractors—use federal investigative standards and OPM internal  guidance as criteria for collecting background information on applicants.  Federal guidelines require that DOD adjudicators use the information  contained in the resulting investigative reports to determine whether an  applicant is eligible for a personnel security clearance.
We first placed DOD’s personnel security clearance program on our high- risk list in 2005. Some of the problems included (1) delays in completing  clearances; (2) incomplete investigative reports from OPM, the agency  that reportedly supplies about 90 percent of all federal clearance  investigations, including those for DOD; and (3) the granting of some  clearances by DOD adjudicators even though required data were missing  from the investigative reports used to make such determinations. We also  reported that delays in issuing clearances can result in millions of dollars  of additional cost to the federal government. Furthermore, during this  period the executive branch initiated actions to reform the  governmentwide security clearance process.
My testimony is based on our issued reports and testimonies on DOD’s  personnel security clearance program and governmentwide suitability and  security clearance reform efforts. Our reports and testimonies were  conducted in accordance with generally accepted government auditing  standards.
subsections: section_title: Leadership Commitment, Improved Timeliness, and Development of Metrics Were Key to Removal of DOD’s Security Clearance Program from GAO’s High-Risk List
paragraphs: Since we identified DOD’s Personnel Security Clearance program as a  high-risk area, DOD, in conjunction with Congress and other executive  agency leadership, took actions that resulted in significant progress  toward resolving problems we identified with the security clearance  program. In 2011, we removed DOD’s personnel security clearance  program from our high-risk list because of the agency’s progress in  improving timeliness and the development of tools and metrics to assess  quality, as well as DOD’s commitment to sustaining progress. Importantly,  congressional oversight and the committed leadership of the Suitability  and Security Clearance Performance Accountability Council  (Performance Accountability Council) –which has been responsible for  overseeing security clearance reform efforts since 2008—greatly  contributed to the progress of DOD and the governmentwide security  clearance reform.
subsections: section_title: Top Leadership Demonstrated Commitment and Collaboration in Reforming Security Clearance Process
paragraphs: Leadership in Congress and the executive branch demonstrated  commitment to reforming the security clearance process to address  longstanding problems associated with the personnel security clearance  program. As we have previously noted, top leadership must be committed  to organizational transformation. Specifically, leadership must set the  direction, pace, and tone and provide a clear, consistent rationale that  brings everyone together behind a single mission. Figure 1 illustrates key  events related to the Suitability and Personnel Security Clearance Reform  Effort.
Congressional legislation and oversight has helped focus attention and  sustain momentum to improve the processing of security clearances not  only for DOD but governmentwide. The Intelligence Reform and  Terrorism Prevention Act of 2004 (IRTPA) established, among other  things, milestones for reducing the time to complete initial clearances. We  previously identified best practices for agencies to successfully transform  their cultures including among other things, setting implementation goals  and a timeline to build momentum and show progress from day one.
IRTPA established an interim objective to be met by December 2006  under which DOD and other agencies that adjudicate security clearances  were to make a decision on at least 80 percent of initial clearance  applications within 120 days, on average. Further, IRTPA called for the  executive branch to implement a plan by December 17, 2009, under  which, to the extent practical, at least 90 percent of decisions are made  on applications for an initial personnel security clearance within 60 days,  on average. Additionally, IRTPA required the executive branch to begin  providing annual reports to Congress in 2006 on the progress made the  preceding year toward meeting IRTPA’s objectives for security  clearances, including the length of time agencies took to complete the  investigations and adjudications—the decision as to whether an individual  should be granted eligibility for a clearance.
GAO has testified on security clearance reform before this committee as well as the (1)  Subcommittee on Intelligence Community Management, House Permanent Select  Committee on Intelligence, (2) the Subcommittee on Government Management,  Organization, and Procurement, House Committee on Oversight and Government Reform,  and (3) Subcommittee on Readiness, House Committee on Armed Services. security clearance reform efforts. After that meeting, OMB, ODNI, DOD,  OPM, and GAO provided a memorandum on May 31, 2010 to Chairman  Akaka containing a matrix with 15 metrics for assessing the timeliness  and quality of investigations, adjudications, reciprocity (an agency’s  acceptance of a background investigation or clearance determination  completed by any authorized investigative or adjudicative agency), and  automation. The development of these metrics played a key role in  GAO’s decision to remove DOD’s Personnel Security Clearance program  from the high-risk list.
Furthermore, we have noted for many years the central role that the  Government Performance and Results Act (GPRA) could play in  identifying and fostering improved coordination across related federal  program efforts. The GPRA Modernization Act of 2010 (GPRAMA) for a more coordinated and crosscutting approach to achieve meaningful  results. GPRAMA provides an opportunity for agencies to collect and  report more timely and useful performance information on crosscutting  programs. This performance information can play an important role in  congressional decision making. In fact, Mr. Chairman, we conducted work  for you focusing on how Congress can use such information to address  challenges facing the government. DOD’s personnel security clearance  program was one of three case studies we used to illustrate how  Congress has used agency performance information in its decision  making.
Pub. L. No. 111-352, 124 Stat. 3886 (2011). GPRAMA amended the Government  Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285 (1993). placed the program on our high-risk list, top executive branch leadership  put in place an effort to reform the security clearance process. For  example, in 2007, DOD and ODNI formed the Joint Security Clearance  Process Reform Team, known as the Joint Reform Team, to improve the  security clearance process governmentwide. Specifically, they tasked  the Joint Reform Team to execute joint reform efforts so that they achieve  IRTPA timeliness goals and improve the processes related to granting  security clearances. In 2008, the President in a memorandum called for  a reform of the security clearance program and subsequently issued an  executive order establishing the Performance Accountability Council.  Under the executive order, this council is accountable to the President for  leading the implementation of reform, including aligning security and  suitability processes, holding agencies accountable for implementation,  and establishing goals and metrics for progress.
DOD worked with the Joint Reform Team and the Performance  Accountability Council to develop a corrective action plan to improve  timeliness and demonstrate progress toward reforming the security  clearance process. For example,
DOD’s leadership, in conjunction with the Joint Reform Team,  developed a plan for reform that continuously evolved to incorporate  new goals and address identified issues. To communicate these  plans, the Joint Reform Team issued an initial reform plan in April  2008 that presented a new seven-step design intended to streamline  the security clearance process, including the use of a more  sophisticated electronic application, a more flexible investigation  process, and the establishment of ongoing evaluation procedures  between formal clearance investigations. The report was updated in  December 2008 to include an outline of reform progress and further  plans, and in March 2009 the Joint Reform Team issued its Enterprise  Information Technology Strategy for the security clearance and  suitability reform program. Then, in line with GAO recommendations,  DOD worked with the Performance Accountability Council to issue a  strategic framework that the council included in its 2010 report to the  President. The strategic framework identified key governmentwide  reform goals and identified the root causes for timeliness delays and  delays to agencies honoring reciprocity. It also set forth a  governmentwide mission, performance measures, a communications  strategy, roles and responsibilities, and metrics to measure the quality  of security clearance investigations and adjudications. DOD continues  to work with the Performance Accountability Council to sustain  clearance reform efforts and enhance transparency and accountability  through annual reporting to Congress.
DOD issued guidance on adjudication standards. In May 2009, we  found that although DOD asserted that adjudicators follow a risk- management approach for granting security clearances, DOD had not  issued formal guidance clarifying if and under what circumstances  adjudicators can adjudicate incomplete investigative reports—such as  missing information relevant to residences, employment, or education.  As a result, we recommended that DOD issue guidance that clarifies  when adjudicators may use incomplete investigative reports as the  basis for granting clearances. Subsequently, on November 8, 2009,  the Under Secretary of Defense for Intelligence issued guidance on  adjudication standards that outline the minimum documentation  requirements adjudicators must adhere to when documenting  personnel security clearance determinations for cases with potentially  damaging information. On March 10, 2010, the Under Secretary of  Defense for Intelligence issued additional guidance 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.  Further, according to DOD officials, in 2010, DOD created a  Performance Accountability Directorate within the Directorate of  Security to provide oversight and accountability for the DOD Central  Adjudication Facilities that process DOD adjudicative decisions.
section_title: DOD Developed Assessment Tools and Performance Metrics and Improved Timeliness to Demonstrate Progress
paragraphs: One of DOD’s key actions that led to the removal of its personnel security  clearance program from our high-risk list was that DOD was able to  demonstrate its progress in having implemented corrective measures.  Longstanding backlogs and delays in the clearance process led to our  initial designation of this area as high risk. For example, in 2004, we  testified that from fiscal year 2001 through fiscal year 2003, the average  time for DOD to determine clearance eligibility for industry personnel  increased by 56 days to over 1 year. In 2005, we reported that DOD  could not estimate the full size of its backlog, but we identified over  350,000 cases exceeding established timeframes for determining  eligibility. Moreover, in 2007 and 2009, we reported that clearances  continued to take longer than the timeliness goals prescribed in IRTPA.
In 2011, we reported that DOD processed 90 percent of initial clearances  in an average of 49 days for federal civilians, military, and industry  personnel and met the 60-day statutory timeliness objective for  processing all initial clearances in fiscal year 2010. Also we found that  DOD completed 90 percent of initial clearances for industry personnel in  an average of 63 days for all the data we reviewed in fiscal year 2010,demonstrating an improvement from what we found in 2004, when the  average processing time for industry personnel was over a year.
Our high-risk designation was based not only on problems with timeliness  but also incomplete documentation of investigations and adjudications.  We reported on missing documentation in investigative reports prepared  by OPM that DOD adjudicators had used to make clearance eligibility  decisions. In 2009, we estimated that 87 percent of about 3,500 OPM  investigative reports provided to DOD in July 2008 were missing required  documentation, which in most cases pertained to residences,  employment, and education. DOD adjudicators granted clearance  eligibility without requesting missing investigative information or fully  documenting unresolved issues in 22 percent of DOD’s adjudicative files.  These findings led us to recommend that OPM and DOD, among other  things, develop and report metrics on completeness and other measures  of quality for investigations and adjudications that address the  effectiveness of the new procedures. DOD agreed and implemented our  recommendations regarding adjudication. OPM neither concurred nor  nonconcurred with our recommendation; however, as noted earlier, OPM  has taken steps to develop metrics.
Subsequently, DOD developed two quality tools to evaluate  completeness of documentation used to determine clearance eligibility.  First, the Rapid Assessment of Incomplete Security Evaluations (RAISE)  tracks the quality of investigations conducted by OPM. Results of RAISE  will be reported to the Director of National Intelligence, which, as the  Security Executive Agent of the Performance Accountability Council, will  arbitrate any potential disagreements between OPM and DOD and clarify  policy questions. DOD deployed RAISE to four Central Adjudication  Facilities from July to October 2010 and planned to complete deployment  to the remaining Central Adjudication Facilities by calendar year 2011.  According to DOD officials, as of June 2012 this tool has been deployed  to all of DOD’s non-intelligence agencies adjudication facilities. Although  the Joint Reform Team is considering using it in the future, it is not being  used by other executive agencies. Second, in 2008 DOD developed the  Review of Adjudication Documentation Accuracy and Rationales  (RADAR), which tracks the quality of clearance adjudications. In 2009,  the Under Secretary of Defense for Intelligence directed DOD Central  Adjudication Facilities to provide adjudication case records to the Defense  Personnel Research Center for analysis. According to DOD officials, the  department plans to use results of the RADAR assessments to monitor  Central Adjudication Facilities’ compliance with documentation policies,  communicate performance to the Central Adjudication Facilities, identify  potential weaknesses and training needs, increase compliance, and  establish trend data. DOD has completed a pilot program for the use of  RADAR and began its implementation for the Army, Defense Industrial  Security Clearance Office, and Navy Central Adjudication Facilities in  September 2010. In addition to these assessment tools, in 2010 DOD,  OMB, ODNI, and OPM developed 15 metrics that assess the timeliness  and quality of investigations, adjudications, reciprocity, and automation.  The quality metrics, in turn, can be used to gauge progress and assess  the quality of the personnel security clearance process. These metrics  represented positive developments that could contribute to greater  visibility over the 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. The  combination of congressional reporting requirements, the strategic  framework, and the development of quality metrics, will help ensure  transparency throughout the reform effort. It is important not only to have  metrics but to use them to guide implementation. By using metrics for  timeliness, DOD was able to show progress over time that helped build  momentum to reach the final goal.
section_title: Continuing Executive Branch Leadership and Management Attention May Enhance the Security Clearance Reform Efforts
paragraphs: DOD’s security clearance reform effort aligned with our criteria for  removal from the high-risk list in fiscal year 2011. However, security  clearance reform extends beyond DOD throughout the executive branch.  This is evidenced by the oversight structure, through the Performance  Accountability Council, and broad executive branch participation in the  reform effort. Building on the factors for reforming the security process  that we have reported in the past, continued leadership and attention,  such as continuing to monitor and update outcome-focused performance  measures, seeking opportunities to enhance efficiency and managing  costs, and ensuring a strong requirements determination process, may  enhance the security clearance reform effort.
subsections: section_title: Implementing, Monitoring, and Updating Outcome- Focused Performance Measures
paragraphs: DOD has developed tools to monitor quality as well as participated in the  development and tracking of quality metrics for OPM’s investigations and  DOD’s adjudications through the Performance Accountability Council. We  view the development of quality metrics as a positive step towards  creating greater visibility over the quality of the clearance process and  identifying specific quantifiable targets linked to goals that can be  measured objectively. Moreover, leaders and others need to use these  metrics to gauge progress toward improvements. Further, the  development of performance measures related to the security clearance  process by the Performance Accountability Council aligns with our  previous recommendation to develop outcome-focused performance  measures to continually evaluate the progress of the reform effort. We  have also previously reported on the importance of continually assessing  and evaluating programs as a good business practice, including  evaluating metrics to help ensure that they are effective and updated  when necessary.the reform and that DOD and OPM complete implementation of the   As a result, it is important to sustain the momentum of  quality tools and metrics so that the executive branch can demonstrate  progress in improving the quality of investigations and adjudications.
Leaders of the reform effort have consistently stated that implementation  of reform will be incremental, and therefore, it is important that the  information necessary to capture performance is up-to-date. The  Performance Accountability Council quality metrics were developed  subsequent to the issuance of the 2010 Strategic Framework, which  articulates the goals of the security and suitability process reform. As a  result, the 2010 Strategic Framework did not include a detailed plan or  guidance for the implementation of the quality metrics. Further, the       May 31, 2010 memorandum in which the Performance Accountability  Council detailed its metrics did not discuss how often the metrics will be  reexamined for continuous improvement. Moreover, according to DOD,  the tools and metrics to assess quality have not been fully implemented.  For example, while DOD has implemented its RAISE tool for investigation  quality, it is not being used by other executive branch agencies— including OPM, which conducts the investigations and would be the  appropriate agency to take actions to improve investigation quality— although the Joint Reform Team is considering using it in the future.  Without these tools and metrics the executive branch will be unable to  demonstrate progress in improving quality.
Emphasis on quality in clearance processes should promote positive  outcomes, including more reciprocity among agencies in accepting each  others’ clearances. Building quality throughout clearance processes is  important, but government agencies have not paid the same attention to  quality as they have to timeliness. The emphasis on timeliness is due in  part to the requirements and objectives established in IRTPA regarding  the speed with which clearances should be completed. Our work has  repeatedly called for more emphasis on quality.
As previously noted, IRTPA required an annual report of progress and  key measurements as to the timeliness of initial security clearances in  February of each year from 2006 through 2011. It specifically required  those reports to include the periods of time required for conducting  investigations, adjudicating cases, and granting clearances. IRTPA  required the executive branch to implement a plan by December 2009 in  which, to the extent practical, 90 percent of initial clearances were  completed within 60 days, on average. In its initial reports, the executive  branch reported only on the average of the fastest 90 percent of  clearances and excluded the slowest 10 percent. We previously reported  that full visibility was limited by the absence of comprehensive reporting  of initial clearance decisions timeliness.  Consistent with our  recommendation, the executive branch began reporting on the remaining  10 percent in its 2010 and 2011 reports. However, the IRTPA requirement  for the executive branch to annually report on its timeliness expired last  year. More recently, in 2010, the Intelligence Authorization Act of 2010  established a new requirement that the President annually report the  total amount of time it takes to process certain security clearance  determinations for the previous fiscal year for each element of the  Intelligence Community.
The Intelligence Authorization Act of 2010 requires, among other things,  annual reports from the President to Congress that include the total  number of active security clearances throughout the United States  government, to include both government employees and contractors. Its  timeliness reporting requirement, however, applies only to the elements of  the Intelligence Community. Unlike the IRTPA reporting requirement, the  requirement to submit these annual reports does not expire. Further, the  Intelligence Authorization Act requires two additional one-time reports:  first, a report to Congress by the President including metrics for  adjudication quality, and second, a report to the congressional  intelligence committees by the Inspector General of the Intelligence  Community on reciprocity. The report containing metrics for adjudication  quality summarizes prior information on developed tools and performance  measures; however, it does not provide additional information on the  implementation or update of the performance measures that were  identified in the May 2010 memorandum on quality metrics. Additionally,  according to an ODNI official, the report on reciprocity has not been  provided, although these reports were required 180 days after the law  was enacted on Oct 7, 2010.
The Intelligence Authorization Act of 2010 reporting requirement on  reciprocity—an agency’s acceptance of a background investigation or  clearance determination completed by any authorized investigative or  adjudicative agency—is the first time the executive branch has been  required to report on this information since the reform effort began.  Further, in 2010 we reported that although there are no governmentwide  metrics to comprehensively track when and why reciprocity is granted or  denied, agency officials stated that they routinely take steps to honor  previously granted security clearances. We found that agencies do not  consistently document the additional steps they have taken prior to  granting a reciprocal clearance. For example, the Navy keeps electronic  documentation, the Department of Energy and the Department of the  Treasury keep paper documentation, and the Army and the Air Force do  not maintain any documentation on the additional steps taken to accept a  previously granted security clearance. Consequently, there is no  consistent tracking of the amount of staff time spent on the additional  actions that are taken to honor a previously granted security clearance.
In addition, agencies do not consistently and comprehensively track the  extent to which reciprocity is granted. OPM has a metric to track  reciprocity, but this metric captures limited information, such as numbers  of requested and rejected investigations, but not the number of cases in  which a previously granted security clearance was or was not honored.  Similarly, the metrics proposed by the Performance Accountability  Council do not track the extent to which reciprocity is or is not ultimately  honored. For example, metrics proposed by the Performance  Accountability Council, such as the number of duplicate requests for  investigations, percentage of applications submitted electronically,  number of electronic applications submitted by applicants but rejected by  OPM as unacceptable because of missing information or forms, and  percentage of fingerprint submissions determined to be “unclassifiable” by  the Federal Bureau of Investigation, provide useful information but do not  track the extent to which reciprocity is or is not ultimately honored.  Without comprehensive, standardized metrics to track reciprocity, and  documentation of the process, decision makers lack a complete picture of  the extent to which reciprocity is granted and the challenges to honoring  previously granted security clearances.
To further improve governmentwide reciprocity, in 2010 we recommended  that the Deputy Director of Management, OMB, in the capacity as Chair of  the Performance Accountability Council, develop comprehensive metrics  to track reciprocity and then report the findings from the expanded  tracking to Congress. OMB generally concurred with our  recommendation, stating that the Performance Accountability Council is  working to develop these additional metrics. According to a 2011 report  on security clearance performance metrics, the executive branch is  making progress toward developing metrics to track reciprocity  specifically with the intelligence community agencies. We are  encouraged by the Performance Accountability Council’s development of  quality metrics, which include some metrics for tracking reciprocity. These  are positive steps that can contribute to greater visibility of the clearance  process, but these measures have not yet been fully implemented or their  effectiveness assessed.
section_title: Enhancing Efficiencies and Managing Costs
paragraphs: Our previous work has highlighted the importance of the executive branch  enhancing efficiency and managing costs related to the reform effort. For  example, in 2008, we noted that one of the key factors to consider in  current and future reform efforts was the long-term funding  requirements. Further, in 2009, we found that reform-related reports did  not detail what reform objectives require funding, how much they will cost,  or where funding will come from. Furthermore, the reports did not  estimate potential cost savings resulting from the streamlined process. At  that time, senior reform leaders stated that cost estimates had not been  completed by the Joint Reform Team or the agencies affected by reform  as it was too early. Accordingly, we recommended that reform leaders  issue a strategic framework that contained the long-term funding  requirements of reform, among other things. Consequently, in February  2010, the Performance Accountability Council issued a strategic  framework that responded to our recommendation; however, that  framework did not detail funding requirements. Instead, it noted that DOD  and OPM would cover costs for major information technology  acquisitions.
As reform leaders, through the Performance Accountability Council,  consider changes to the current clearance processes, they should ensure  that Congress is provided with the long-term funding requirements  necessary to implement any such reforms. Those funding requirements to  implement changes to security clearance processes are necessary to  enable the executive branch to compare and prioritize alternative  proposals for reforming the clearance processes. For example, DOD  officials told us that it was unable to conduct quality assessment of  adjudications during fiscal year 2011 due to lack of funding. In addition,  DOD officials noted that the department is using its tool to assess the  quality of investigations. However, there is no evidence that this tool is  being used by other agencies to assess the quality of investigations.  Given current fiscal constraints, identifying the long-term costs is critical  for decision-makers to compare and prioritize alternative proposals for  completing the transformation of the security clearance process. Without  information on longer-term funding requirements necessary to implement  the reform effort, Congress lacks the visibility it needs to fully assess  appropriations requirements. We most recently reported on two areas of  opportunity for which the executive branch may be able to identify  efficiencies: information technology and investigation and adjudication  case management and processes.
In February 2012, we reported that information technology investments  were one of OPM’s background investigations programs’ three main cost  drivers. While these investments represent less than 10 percent of  OPM’s fiscal year 2011 reported costs, they have increased more than  682 percent over 6 years (in fiscal year 2011 dollars), from about $12  million in fiscal year 2005 to over $91 million in fiscal year 2011.  Moreover, we reported that OPM’s investigation process reverts its  electronically-based investigation back into paper-based files. In  November 2010, the Deputy Director for Management of the Office of  Management and Budget testified that OPM now receives over 98  percent of investigation applications electronically, yet we observed that it  is continuing to use a paper-based investigation processing system and  converts electronically submitted applications to paper. OPM officials  stated that the paper-based process is required because a small portion  of their customer agencies do not have electronic capabilities.  Furthermore, OPM’s process has not been studied to identify efficiencies.  As a result, OPM may be simultaneously investing in process  streamlining technology while maintaining a less-efficient and duplicative  paper-based process. We recommended that OPM take actions to  identify process efficiencies, including its use of information technology to  complete investigations, which could lead to cost savings within its  background investigation processes. OPM concurred with our  recommendation and commented that these actions also reinforce a  Federal Investigative Services priority and that the agency will continue to  map its process to achieve maximum process efficiencies and identify  potential cost savings. In commenting on our final report, OPM stated in a  May 25, 2012 letter to us that it is taking a number of actions that could  lead to cost savings within its background investigation process. For  example, OPM noted it is conducting a study of business processes  identifying time savings and efficiencies for future Federal Investigative  Services’ business processes which will conclude by December 2013.
In February 2012, as part of our annual report on opportunities to reduce  duplication, overlap and fragmentation, we reported that multiple  agencies have invested in or are beginning to invest in potentially  duplicative, electronic case management and adjudication systems  despite governmentwide reform effort goals that agencies leverage  existing technologies to reduce duplication and enhance reciprocity.  According to DOD officials, DOD began the development of its Case  Adjudication Tracking System in 2006 and, as of 2011, invested a total of  $32 million to deploy the system. The system helped DOD achieve  efficiencies with case management and an electronic adjudication module  for secret level cases that did not contain issues, given the volume and  types of adjudications performed. According to DOD officials, after it  observed that the Case Adjudication Tracking System could easily be  deployed to other agencies at a low cost, the department intended to  share the technology with interested entities across the federal  government. For example, the Department of Energy is piloting the  electronic adjudication module of DOD’s system, and, according to DOD  officials, the Social Security Administration is also considering adopting  the system. In addition to DOD, Department of Justice officials said they  began developing a similar system in 2007 at a cost of approximately $15  million. In an effort to better manage the adjudication portion of the  suitability and security clearance process, agencies have transitioned or  plan to transition from a paper-based to an electronic adjudication case- management system. Although the investment in electronic case- management systems will likely lead to process efficiencies, agencies  may not be leveraging adjudication technologies in place at other  executive branch agencies to minimize duplication.
One of these other agencies, the National Reconnaissance Office, is itself a component  of DOD. would have to initially invest approximately $300,000 for implementation,  plus any needed expenditures related to customizations, and long-term  support and maintenance, which could require approximately $100,000  per year.
Officials from OPM, one of the five other agencies developing or seeking  funds to develop similar systems, explained that they plan to develop an  electronic case-management system that is synchronized with its  governmentwide background investigations system that would be  available for their customer agencies to purchase. OPM released a  request for information to evaluate the options for this system. DOD  responded to OPM’s request for information by performing a comparative  analysis of its own case-management system and said that it believes its  system meets the needs set out in OPM’s request for information.  However, OPM officials said that DOD’s system would cost too much  money for smaller agencies to adopt, so OPM plans to continue exploring  other options that would allow customer agencies access to their  electronic case-management system without the need to make an  expensive initial investment. Additionally, OPM officials said that their  effort is intended to promote process efficiency by further integrating OPM  with its more than 100 customer agencies. However, some OPM  customer agencies, including DOD, which makes up approximately 75  percent of OPM’s investigation workload, expressed concern that such a  system would likely be redundant to currently available case- management technology. Further, any overhead costs related to the  development of an OPM system would be incorporated into OPM’s  operating costs, which could affect investigation prices.
The investment in electronic case-management systems aligns with the  reform effort’s goal to automate information technology capabilities to  improve the timeliness, efficiency, and quality of existing security  clearance and suitability determinations systems. It also will likely lead to  process efficiencies; however, agencies may be unclear how they might  achieve cost savings through leveraging adjudication technologies in  place at other executive branch agencies. In its March 2009 Enterprise  Information Technology Strategy, the Joint Reform Team stated that  agencies will leverage existing systems to reduce duplication and  enhance reciprocity. Moreover, the Performance Accountability Council is  positioned to promote coordination and standardization related to the  suitability and security clearance process through issuing guidance to the  agencies. The reform effort’s strategic framework includes cost savings in  its mission statement, but this framework lacks specificity regarding how  agencies might achieve costs savings. Without specific guidance, the  opportunities to minimize duplication and achieve cost savings may be  lost. Therefore, in 2012 we recommended that OMB as the Chair of the  Performance Accountability Council expand and specify reform-related  guidance to help ensure that reform stakeholders identify opportunities for  cost savings, such as preventing duplication in the development of  electronic case management.OMB concurred with our recommendation.
section_title: A Sound Requirements Process for Determining Required Clearances and Level of Clearances May Reduce Costs
paragraphs: In February 2008 and in subsequent reports, we have noted the  importance of having a sound requirements determination process for  security clearances. Specifically, a sound requirements determination  process may help ensure that workload and costs are not higher than  necessary. Further, the Performance Accountability Council’s reformed  security clearance process identified determining if a position requires a  security clearance as the first step of the process. Specifically, the  clearance process begins with establishing whether a position requires a  clearance, and if so, at what level. The numbers of requests for initial and  renewal clearances and the levels of such clearance requests are two  ways to look at outcomes of requirements setting in the clearance  process. As of October 2010, the Director of National Intelligence  reported that 3.9 million federal employees (military and civilian) and  contractors hold security clearances. Moreover, OPM reported that its  cost to conduct background investigations for much of the executive  branch outside the intelligence agencies increased about 79 percent from  about $602 million in fiscal year 2005 to over $1.1 billion in fiscal year  2011.
In our prior work, DOD personnel, investigations contractors, and industry  officials told us that the large number of requests for investigations could  be attributed to many factors. For example, they ascribed the large  number of requests to the heightened security concerns that resulted  from the September 11, 2001, terrorist attacks. They also attributed the  large number of investigations to an increase in the operations and  deployments of military personnel and to the increasingly sensitive  technology that military personnel, government employees, and  contractors come in contact with as part of their jobs. Having a large  number of cleared personnel can give the military services, agencies, and  industry a great deal of flexibility when assigning personnel, but the  investigative and adjudicative workloads that are required to provide  clearances and that flexibility further tax the clearance process.
A change in the higher level of clearances being requested also increases  the investigative and adjudicative workloads. For example, top secret  clearances must be renewed twice as often as secret clearances (i.e.,  every 5 years versus every 10 years). More specifically, the average  investigative report for a top secret clearance takes about 10 times as  many investigative staff hours as the average investigative report for a  secret clearance. As a result, the investigative workload increases about  20-fold. Additionally, the adjudicative workload increases about 4-fold,  because in our previous work, DOD officials estimated that investigative  reports for a top secret clearance took about twice as long to review as an  investigative report for a secret clearance. Further, a top secret clearance  needs to be renewed twice as often as the secret clearance. In August  2006, OPM estimated that approximately 60 total staff hours are needed  for each investigation for an initial top secret clearance and 6 total staff  hours are needed for the investigation to support a secret or confidential  clearance. The doubling of the frequency along with the increased effort  to investigate and adjudicate each top secret reinvestigation adds costs  and workload for the government.
For fiscal year 2012, OPM’s standard base prices are $4,005 for an  investigation for an initial top secret clearance; $2,711 for an investigation  to renew a top secret clearance, and either $228 or $260 for an  investigation for a secret clearance. As we reported in February 2012,  these base prices can increase if triggered by the circumstances of a  case, such as issues related to credit or criminal history checks. For  example, in 2011, DOD officials stated that the prices contained in OPM’s  Federal Investigative Notices are not always reflective of the amount  DOD actually pays for an investigation, as a result of these  circumstances. Further, the cost of getting and maintaining a top secret  clearance for 10 years is almost 30 times greater than the cost of getting  and maintaining a secret clearance for the same period. For example, an  individual getting a top secret clearance for the first time and keeping the  clearance for 10 years would cost the government a total of $6,716 in  current year dollars ($4,005 for the initial investigation and $2,711 for the  reinvestigation after the first 5 years). In contrast, an individual receiving a  secret clearance and maintaining it for 10 years would result in a total  cost to the government of $228 ($228 for the initial clearance that is good  for 10 years). Requesting a clearance for a position in which it will not be  needed, or in which a lower level clearance would be sufficient, will  increase investigative workload and thereby costs unnecessarily. We are  currently reviewing the process that the executive branch uses to  determine whether a position requires a security clearance for the  Ranking Member of the House Committee on Homeland Security, and the  expected issuance date for this report is this summer.
In conclusion, Mr. Chairman, Mr. Johnson, and Members of the  Subcommittee, as evidenced by our removal of the DOD’s security  clearance program from our high-risk list, we are strongly encouraged by  the progress that the Performance Accountability Council, and in  particular, DOD, has made over the last few years. DOD has shown  progress by implementing recommendations, improving overall  timeliness, and taking steps to integrate quality into its processes. The  progress that has been made with respect to the overall governmentwide  reform efforts would not be possible without committed and sustained  leadership of Congress and by the senior leaders involved in the  Performance Accountability Council as well as their dedicated staff.  Continued oversight and stewardship of the reform efforts is the  cornerstone to sustaining momentum and making future progress. As the  executive branch continues to move forward to enhance the suitability  and security clearance reform, the actions to monitor quality and enhance  efficiency will be key to enhance the progress made on timeliness to date.
Chairman Akaka, Ranking Member Johnson, and Members of the  Subcommittee, this concludes my prepared statement, and I would be  pleased to answer any questions that you may have. Thank you.
For further information on this testimony, please contact Brenda S.  Farrell, Director, Defense Capabilities and Management, who may be  reached at (202) 512-3604. Contact points for our Congressional  Relations and Public Affairs offices may be found on the last page of this  statement. GAO staff who made key contributions to this testimony  include Lori Atkinson (Assistant Director), Grace Coleman, Sara Cradic,  James Krustapentus, Gregory Marchand, Jillena Roberts, and Amie  Steele.
section_title: Related GAO Products
paragraphs: 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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