Personnel Security Clearances: Actions Needed to Ensure Quality of Background Investigations and Resulting Decisions
Published: 2014-02-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Recently the DNI reported that more than 5.1 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 for federal employment) in fiscal year 2011. A high quality process is essential to minimize the 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.
This statement addresses (1) a general overview of the security clearance process; (2) what is known about the quality of investigations and adjudications, which are the determinations made by executive branch agency officials to grant or reject clearance requests based on investigations; and (3) the extent of reciprocity, which is the decision of agencies to honor clearances previously granted by other agencies. This statement is based on GAO work issued from 2008 to 2013 on DOD's personnel security clearance program and government-wide suitability and security clearance reform efforts. As part of that work, GAO (1) reviewed relevant 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 a sample of case files for DOD personnel.
section_title: What GAO Found
paragraphs: Several agencies have key roles and responsibilities in the multi-phased personnel security clearance process, including the Director of National Intelligence (DNI) who, as the Security Executive Agent, is responsible for developing policies and procedures related to security clearance investigations and adjudications, among other things. The Deputy Director for Management at the Office of Management and Budget chairs the Performance Accountability Council that oversees reform efforts to enhance the personnel security process. The security process includes: the determination of whether a position requires a clearance, application submission, investigation, and adjudication. Specifically, agency officials must first determine whether a federal civilian position requires access to classified information. After an individual has been selected for a position that requires a personnel security clearance and the individual submits an application for a clearance, investigators—often contractors—from the Office of Personnel Management (OPM) conduct background investigations for most executive branch agencies. Adjudicators from requesting agencies use the information from these investigations and federal adjudicative guidelines to determine whether an applicant is eligible for a clearance. Further, individuals are subject to reinvestigations at intervals based on the level of security clearance.
Executive branch agencies do not consistently assess quality throughout the personnel security clearance process, in part because they have not fully developed and implemented metrics to measure quality in key aspects of the process. For more than a decade, GAO has emphasized the need to build and monitor quality throughout the clearance process to promote oversight and positive outcomes such as maximizing the likelihood that individuals who are security risks will be scrutinized more closely. GAO reported in 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, the required number of social references for the applicant, and complete security forms. In May 2009, GAO recommended that OPM measure the frequency with which its investigative reports met federal investigative standards to improve the completeness—that is, quality—of investigation documentation. In January 2014, DNI officials said that metrics to measure quality of investigative reports had not been established.
GAO reported in 2010 that executive branch agencies do not consistently and comprehensively track the extent to which reciprocity is occurring because no government-wide metrics exist to consistently and comprehensively track when reciprocity is granted. The acceptance of a background investigation or personnel security clearance determination completed by another authorized agency is an opportunity to save resources and executive branch agencies are required by law to grant reciprocity, subject to certain exceptions, such as completing additional requirements like polygraph testing. GAO's 2010 recommendation that the leaders of the security clearance reform effort develop metrics to track reciprocity has not been fully implemented.

section_title: Letter
paragraphs: Thank you for the opportunity to comment on the federal government’s  approach to background investigations. As you know, we have an  extensive body of work on issues related to the personnel security  clearance process. Since 2008, we have focused on the government- wide effort to reform the security clearance process. 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 histories of 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 there is more work to be done by federal agencies to help ensure  that the clearance process functions effectively and efficiently, so that  only trustworthy individuals obtain and keep security clearances and the  resulting access to classified information.
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 or 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  that 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. Recently, the Director of National  Intelligence (DNI) reported that as of October 2013, more than 5.1 million  federal government and contractor employees held or were eligible to  hold a security clearance. Furthermore, we have reported that 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—788,000 background investigations that cost over  $787 million in fiscal year 2011.
My statement today will focus on three topics related to personnel  security clearances. First, I will provide a general overview of the security  clearance process, including how clearances are acquired and retained.  Second, I will discuss what is known about the quality of clearance  investigations and adjudications, which are the determinations made by  agency officials to grant or reject clearance requests based on  investigations. Third, I will discuss the extent of reciprocity, which is the  decision of agencies to honor clearances previously granted by other  agencies.
My statement 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 relevant 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 statement 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. Additional details about the  scope and methodology can be found in each of these related products.
subsections: section_title: The Personnel Security Clearance Process
paragraphs: Multiple executive-branch agencies are responsible for different phases 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 and 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 the USD(I), manages and administers the DOD portion of  the National Industrial Security Program for the DOD components and  other federal services by agreement, as well as providing security  education and training, among other things.
The Intelligence Reform and Terrorism Prevention Act of 2004 prompted  government-wide suitability and security clearance reform. 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,  including 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.
Pub. L. No. 108-458 (2004) (relevant sections codified at 50 U.S.C. § 3341).
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 (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: To help ensure the trustworthiness and reliability of personnel in positions  with access to classified information, executive branch agencies rely on a  personnel security clearance process that includes multiple phases:  requirements determination, application, investigation, adjudication,  appeals (if applicable, where a clearance has been denied), and  reinvestigation (where applicable, for renewal or upgrade of an existing  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. While different departments and agencies may  have slightly different personnel security clearance processes, the phases  that follow are illustrative of a typical process.
section_title: Requirements Determination Phase
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.
A sound requirements determination 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 resultant  costs. In addition to cost implications, limiting the access to classified  information and reducing the associated risks to national security  underscore the need for executive branch agencies to have a sound  process to determine which positions require a security clearance.
In 2012, we reported that the DNI, as the Security Executive Agent, had  not provided agencies with 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.
We routinely monitor the status of agency actions to address our prior  report recommendations. As part of that process, we found that a January  25, 2013 presidential memo authorized the DNI and OPM to jointly issue  revisions to part 732 of Title 5 of the Code of Federal Regulations, which  provides requirements and procedures for the designation of national  security positions. Subsequently, ODNI and OPM drafted the proposed  regulation; published it in the Federal Register on May 28, 2013; and the  comment period closed. We reported on October 31, 2013 that ODNI and  OPM officials stated that they would jointly review and address comments  and prepare the final rule for approval from the Office of Management and  Budget.
section_title: Application Phase
paragraphs: Once an applicant is selected for a position that requires a personnel  security clearance, a security clearance must be obtained in order for an  individual to gain access to classified information. To determine whether  an investigation would be required, the agency requesting a security  clearance investigation conducts a check of existing personnel security  databases to determine whether there is an existing security clearance  investigation underway or whether the individual has already been  favorably adjudicated for a clearance in accordance with current  standards. 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.
section_title: Investigation Phase
paragraphs: 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 is 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 requesting agencies for their  internal adjudicators.
In December 2012, ODNI and OPM jointly issued a revised version of the  federal investigative standards for the conduct of background  investigations for individuals who work for or on behalf of the federal  government. According to October 31, 2013, testimony by an ODNI  official, the revised standards will be implemented through a phased  approach beginning in 2014 and continuing through 2017.
section_title: Adjudication and Appeals Phases
paragraphs: During the adjudication phase, adjudicators from the hiring agency use  the information from the investigative report along with federal  adjudicative guidelines 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 under way to review the process for security  clearance revocations. We expect to issue a report on this process in the  spring of 2014.
section_title: Reinvestigation Phase
paragraphs: Once an individual has obtained a personnel security clearance and as  long as he or she remains in a position that requires access to classified  national security information, that individual is reinvestigated periodically  at intervals that depend 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 continuing 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 or similar  positions and at least once every 5 years for secret or similar positions,  as a means to reveal security-relevant information earlier than the  previous method, and provide increased scrutiny of populations that could  potentially represent risk to the government because they already have  access to classified information. The revised federal investigative  standards state that the top secret level of security clearances may be  subject to continuous evaluation.
section_title: Actions Needed to Ensure Quality of Clearance Investigations and Adjudications
paragraphs: Executive branch agencies do not consistently assess quality throughout  the personnel security clearance process, in part because they have not  fully developed and implemented metrics to measure quality in key  aspects of the process. We have emphasized—since the late 1990s—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, in 2008 two of the key factors we  identified to consider in efforts to reform the security clearance process  were building quality into every step of the clearance processes and  having a valid set of metrics for evaluating efficiency and effectiveness.We have begun additional work to review the quality of investigations.
GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.: Jan. 2005). Every  2 years at the start of a new Congress, GAO issues a report that identifies government  operations that are high risk because of their vulnerabilities to fraud, waste, abuse, and  mismanagement, or are most in need of transformation to address economy, efficiency, or  effectiveness. percent of all federal clearance investigations, including those for DOD;  and (2) the granting of some clearances by DOD adjudicators even  though some required data were missing from the investigative reports  used to make such determinations.
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 decision 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  investigative reports did not contain a required personal subject interview.  Officials within various executive branch agencies have noted to us that  the information gathered during the interview and investigative portion of  the process is essential for making adjudicative decisions.
Department of Defense, DOD Personnel Security Program Regulation 5200.2-R  (January 1987, incorporating changes Feb. 23, 1996). ability to explain the extent to which or the reasons why some files are  incomplete.
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.
As a result of the incompleteness of OPM’s investigative reports on DOD  personnel and the incompleteness of DOD’s adjudicative files that we first  identified in our 2009 report, we made several recommendations to OPM  and DOD. We recommended 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. OPM did not agree or disagree with  our recommendation.
In a subsequent February 2011 report, we noted that the Office of  Management and Budget, ODNI, DOD, and OPM leaders had provided  congressional members and executive branch agencies with metrics to  assess the quality of investigative reports and adjudicative files and other  aspects of the clearance 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, in June 2012 an OPM  official said that OPM chose not to use this tool and opted to develop  another tool. We currently have work under way to review any actions  OPM has taken to develop and implement metrics for measuring the  completeness of OPM’s investigative reports. However, ODNI officials  confirmed in January 2014 that OPM did not have such metrics in place.
According to OPM officials, OPM also continues to assess 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. 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 affect timeliness.  Further, relying on agencies to voluntarily provide information on  investigation quality may not reflect the quality of OPM’s total  investigation workload.
We also recommended in 2009 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.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 DOD 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   In  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  because of funding shortfalls. DOD restarted the use of RADAR in fiscal  year 2012.
subsections: section_title: Recent Efforts and Sustained Leadership Could Facilitate Progress in Assessing Quality
paragraphs: Several efforts are underway to review the security clearance process,  and those efforts, combined with sustained leadership attention, could  help facilitate progress in assessing and improving the quality of the  security clearance process. After the September 16, 2013 shooting at the  Washington Navy Yard, the President directed the Office of Management  and Budget, in coordination with ODNI and OPM, to conduct a  government-wide review into the oversight, nature, and implementation of  security and suitability standards for federal employees and contractors.  In addition, in September 2013, the Secretary of Defense directed an  independent review to identify and recommend actions that address gaps  or deficiencies in DOD programs, policies, and procedures regarding  security at DOD installations and the granting and renewal of security  clearances for DOD employees and contractor personnel. The primary  objective of this review is to determine whether there are weaknesses in  DOD programs, policies, or procedures regarding physical security at  DOD installations and the security clearance and reinvestigation process  that can be strengthened to prevent a similar tragedy.
We initially placed DOD’s personnel security clearance program on our  high-risk list in 2005 because of delays in completing clearances. 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, the Comptroller General noted in June 2012 that  sustained leadership would be necessary to continue to implement,  monitor, and update outcome-focused performance measures.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 has 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.  However, if the oversight and leadership that helped address the  timeliness issues focuses now on the current problems associated with  quality, we believe that progress in helping executive branch agencies to  assess the quality of the security clearance process could be made.
section_title: Extent of Clearance Reciprocity Is Not Measured
paragraphs: 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. In addition to establishing objectives for  timeliness, the Intelligence Reform and Terrorism Prevention Act of 2004  established requirements for reciprocity, which is an agency’s acceptance  of a background investigation or clearance determination completed by  any authorized investigative or adjudicative executive branch agency,  subject to certain exceptions such as completing additional requirements  like polygraph testing. Further, in October 2008, ODNI issued guidance  on the reciprocity of personnel security clearances. The 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 stated that they  routinely honor other agencies’ security clearances, and personnel  security clearance information is shared between OPM, DOD, and, to  some extent, Intelligence Community databases.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   However, we found  steps to ensure that 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, we reported in 2010 that according to agency officials since there  is no government-wide standardized training and certification process for  investigators and adjudicators, 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 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.
Because of these issues identified by agency officials as hindrances to  reciprocity and because the extent of reciprocity was unknown, 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 the Office of Management and Budget 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 ODNI  report stated that data fields necessary to collect the information  described above do not currently reside in any of the data sets available,  and the process was completed in an agency-specific, semimanual  method.
The Deputy Assistant Director for Special Security of ODNI noted in  testimony in June 2012 that measuring reciprocity is difficult, and despite  an abundance of anecdotes, real data are hard to come by. To address  this problem, in 2013 ODNI planned to develop a web-based form for  individuals to use to submit their experience with reciprocity issues to  ODNI. According to ODNI, this would allow it to collect empirical data,  perform systemic trend analysis, and assist agencies with achieving  workable solutions. However, in January 2014, ODNI officials told us that  required resources and information technology were not available to  support the development and implementation of a web-based form.  Instead, ODNI is conducting a Reciprocity Research Study that will  involve, among other things, agencies identifying their ability to collect  reciprocity metrics. This study would assist ODNI in developing reciprocity  performance measures and a new policy for reciprocity. ODNI would also  use the study to determine if a web-based form would be of value.
In conclusion, to avoid the risk of damaging, unauthorized disclosures of  classified information, oversight of the reform efforts to measure and  improve the quality of the security clearance process is imperative. The  progress that was made with respect to reducing the amount of time  required for 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.
Further, ensuring the quality of personnel security clearance  investigations and adjudications is important government-wide, not just  for DOD. While reciprocity is required by law and, if implemented  correctly, could enhance efficiency and present cost savings  opportunities, much is unknown about the extent to which previously  granted security clearance investigations and adjudications are honored  government-wide. Therefore, we recommended that metrics are needed  to track reciprocity, which have yet to be fully developed and  implemented. Assurances that all clearances are of a high quality may  further encourage reciprocity of investigation and adjudications. We will  continue to monitor the outcome of the agency actions discussed above  to address our outstanding recommendations.
Chairman Issa, Ranking Member Cummings and Members of the  Committee, this concludes my statement for the record.
section_title: GAO Contact and Staff Acknowledgements
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 Margaret Best (Assistant Director), Lori Atkinson,  Kevin Copping, Elizabeth Hartjes, Jeffrey Heit, Suzanne Perkins, Amie  Steele, Erik Wilkins-McKee, and Michael Willems.
section_title: Related GAO Products
paragraphs: Personnel Security Clearances: Actions Needed to Help Ensure Correct  Designations of National Security Positions. GAO-14-139T. Washington,  D.C.: November 20, 2013.
Personnel Security Clearances: Opportunities Exist to Improve Quality  Throughout the Process. GAO-14-186T. Washington, D.C.: November  13, 2013.
Personnel Security Clearances: Full Development and Implementation of  Metrics Needed to Measure Quality of Process. GAO-14-157T.  Washington, D.C.: October 31, 2013.
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.  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,  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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