DOD Personnel Clearances: Additional OMB Actions Are Needed to Improve the Security Clearance Process
Published: 2006-09-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The damage that unauthorized disclosure of classified information can cause to national security necessitates the prompt and careful consideration of who is granted a security clearance. However, long-standing delays and other problems with DOD's clearance program led GAO to designate it a high-risk area in January 2005. DOD transferred its investigations functions to the Office of Personnel Management (OPM) in February 2005. The Office of Management and Budget's (OMB) Deputy Director for Management is coordinating governmentwide efforts to improve the clearance process. Congress asked GAO to examine the clearance process for industry personnel. This report addresses the timeliness of the process and completeness of documentation used to determine the eligibility of industry personnel for top secret clearances. To assess timeliness, GAO examined 2,259 cases of personnel granted top secret eligibility in January and February 2006. For the completeness review, GAO compared documentation in 50 randomly sampled initial clearances against federal standards.
section_title: What GAO Found
paragraphs: GAO's analysis of timeliness data showed that industry personnel contracted to work for the federal government waited more than one year on average to receive top secret clearances, longer than OPM-produced statistics would suggest. GAO's analysis of 2,259 cases in its population showed the process took an average of 446 days for initial clearances and 545 days for clearance updates. While OMB has a goal for the application-submission phase of the process to take 14 days or less, it took an average of 111 days. In addition, GAO's analyses showed that OPM used an average of 286 days to complete initial investigations for top secret clearances, well in excess of the 180-day goal specified in the plan that OMB and others developed for improving the clearance process. Finally, the average time for adjudication (determination of clearance eligibility) was 39 days, compared to the 30-day requirement that starts in December 2006. An inexperienced investigative workforce, not fully using technology, and other causes underlie these delays. Delays may increase costs for contracts and risks to national security. In addition, statistics from OPM, the agency with day-to-day responsibility for tracking investigations and adjudications, underrepresent the time used in the process. For example, the measurement of time does not start immediately upon the applicant's submission of a request for clearance. Not fully accounting for all the time used in the process hinders congressional oversight of the efforts to address the delays. OPM provided incomplete investigative reports to DOD, and DOD personnel who review the reports to determine a person's eligibility to hold a clearance (adjudicators) granted eligibility for industry personnel whose investigative reports contained unresolved issues, such as unexplained affluence and potential foreign influence. In its review of 50 investigative reports for initial clearances, GAO found that that almost all (47 of 50) cases were missing documentation required by federal investigative standards. At least half of the reports did not contain the required documentation in three investigative areas: residence, employment, or education. Moreover, federal standards indicate expansion of investigations may be necessary to resolve issues, but GAO found at least one unresolved issue in 27 of the reports. We also found that the DOD adjudicators granted top secret clearance eligibility for all 27 industry personnel whose investigative reports contained unresolved issues without requesting additional information or documenting that the information was missing in the adjudicative report. In its November 2005 assessment of the government plan for improving the clearance process, GAO raised concerns about the limited attention devoted to assessing quality in the clearance process, but the plan has not been revised to address the shortcomings GAO identified. The use of incomplete investigations and adjudications in granting top secret clearance eligibility increases the risk of unauthorized disclosure of classified information. Also, it could negatively affect efforts to promote reciprocity (an agency's acceptance of a clearance issued by another agency) being developed by an interagency working group headed by OMB's Deputy Director.

section_title: Letter
paragraphs: The critical nature of the information that the Department of Defense  (DOD) and other federal agencies maintain and the damage to national  security that can result if it is not adequately safeguarded necessitate  scrupulous decision making when granting security clearances. With  clearances, personnel can gain access to classified information which  could cause damage to U.S. national defense or foreign relations through  unauthorized disclosure. In our 1999 report, we noted that these serious  negative consequences have included intelligence personnel being killed,  critical information being compromised, and U.S. military forces being put  at risk.
DOD’s Office of the Under Secretary of Defense for Intelligence   has overall responsibility for DOD clearances, and its responsibilities  extend beyond DOD. Specifically, that office’s responsibilities include  obtaining background investigations and using that information to  determine eligibility for a clearance for industry personnel in 23 other  federal agencies, as well as the clearances of staff in the federal  government’s legislative branch. As of May 2006, industry personnel held  about 34 percent of the approximately 2.5 million DOD-maintained  personnel security clearances. Individuals working for private industry are  playing an increasingly larger role in national security work conducted by  DOD and other federal agencies as a result of an increased awareness of  threats to our national security stemming from the terrorist attacks on the  United States on September 11, 2001, and increased efforts over the past  decade to privatize federal jobs.
In February 2005, DOD transferred its personnel security investigations  functions and about 1,800 investigative positions to the Office of Personnel  Management (OPM). Now, DOD obtains nearly all of its clearance  investigations from OPM, which is currently responsible for 90 percent of  the personnel security clearance investigations in the federal government.  DOD retained responsibility for adjudication (determination of eligibility  for a clearance) of military personnel, DOD civilians, and industry  personnel. Two offices are responsible for adjudicating cases involving  industry personnel. The Defense Industrial Security Clearance Office  (DISCO) within OUSD(I) adjudicates cases that contain only favorable  information or minor issues regarding security concerns (e.g., some  overseas travel by the individual), and the Defense Office of Hearings and  Appeals (DOHA) within the Defense Legal Agency adjudicates cases that  contain major security issues (e.g., an individual’s unexplained affluence  or criminal history) which could result in the denial of clearance eligibility.
Long-standing delays in completing hundreds of thousands of clearance  requests for servicemembers, federal employees, and industry personnel  as well as numerous impediments that hindered DOD’s ability to  accurately estimate and eliminate its clearance backlog led us to declare  DOD’s personnel security clearance program a high-risk area in January  2005. The 25 areas on our high-risk list at that time received their  designation because they are major programs and operations that need  urgent attention and transformation in order to ensure that our national  government functions in the most economical, efficient, and effective  manner possible.
Other recent significant events affecting DOD’s clearance program have  been the passage of the Intelligence Reform and Terrorism Prevention Act  of 2004 (IRTPA) and the issuance of the June 2005 Executive Order No.  13381, Strengthening Processes Relating to Determining Eligibility for  Access to Classified National Security Information. IRTPA included  milestones for reducing the time to complete clearances, general  specifications for a database on security clearances, and requirements for  reciprocity of clearances (the acceptance of a clearance and access  granted by another department, agency, or military service). Not later than  December 17, 2006, IRTPA requires agencies to make a determination of  eligibility for a clearance on at least 80 percent of all applications within  an average of 120 days after the date of receipt of the application, with a  maximum of 90 days allotted for the investigation and a maximum of 30  days allotted for the adjudication.
Among other things, Executive Order 13381 stated that the Office of  Management and Budget (OMB) was to ensure the effective  implementation of policy related to appropriately uniform, centralized,  efficient, effective, timely, and reciprocal agency functions relating to  determining eligibility for access to classified national security  information. In June 2005, OMB’s Deputy Director of Management was  designated as the OMB official responsible for improving the process by  which the government determines eligibility for access to classified  national security information. Since then, the Deputy Director has testified  before Congress multiple times about efforts to improve the security  clearance process and has taken positive actions, such as establishing an  interagency working group to improve the reciprocal acceptance of  clearances issued by other agencies and taking a lead role in preparing a  strategic plan to improve personnel security clearance processes  governmentwide. The plan included quarterly timeliness goals for initial  investigations of clearances for the 13 months between the issuance of the  plan and the date on which agencies are to begin comparisons against the  IRTPA timeliness requirements. For January through March 2006 (which  includes the period covered by the data used in our analyses), the plan  specified goals of 180 days to complete investigations for initial top secret  clearances and 130 days to complete investigations for initial secret and  confidential clearances. Goals were not provided for completing  investigations for clearance updates, and the plan indicated that  adjudications would be compared against the future IRTPA requirement of  80 percent completed within 30 days of receipt.
Problems in the clearance program can negatively affect national security.  For example, delays reviewing security clearances for personnel who are  already doing classified work can lead to a heightened risk of disclosure of  classified information. In contrast, delays in providing initial security  clearances for previously noncleared personnel can result in other  negative consequences, such as additional costs and delays in completing  national security-related contracts, lost-opportunity costs, and problems  retaining the best qualified personnel. Moreover, our reports in 1999 and  2001 noted that when clearance investigations or adjudications are  inadequately or inconsistently documented, DOD was unable to  demonstrate that it fully considered all significant adverse conditions that  might call into question an individual’s ability to adequately safeguard  classified information. Similar concerns about the broader issue of quality  were identified more recently in the government plan to improve the  clearance process. More specifically, the November 2005 government wide  plan to improve the security clearance process noted that “a lack of  reciprocity [the acceptance of a clearance and access granted by another  department, agency or military service] often arises due to reluctance of  the gaining activity to inherit accountability for what may be an  unacceptable risk due to poor quality investigations and/or  adjudications.”
You expressed concern about the negative consequences of untimely,  inadequate, or inconsistent investigations and adjudications. This report  addresses two questions: (1) How timely are the processes used to  determine whether industry personnel are eligible for a top secret  clearance? and (2) How complete is the documentation of the processes  used to determine whether industry personnel are eligible for a top secret  clearance? This report supplements the information we provided to you  recently in congressional hearings that examined various aspects of DOD’s  personnel security clearance program (see the list of Related GAO  Products at the end of this report).
The scope of our work emphasized the analysis of information on top  secret clearances awarded to industry personnel, but we also gathered  additional information on other levels of clearances and clearance  requests from other types of personnel in order to provide a broader  context for understanding our primary findings. For both key questions,  we reviewed laws, executive orders, policies, and reports related to the  timeliness and completeness of security clearance investigations and  adjudications for industry personnel as well as servicemembers and  civilian governmental employees. Those sources provided the criteria used  for assessing timeliness and documentation completeness, as well as  identified causes for and effects from delayed clearances and incomplete  investigative and adjudicative reports. Additional insights about causes of  and effects from delayed clearances and incomplete investigative and  adjudicative reports were obtained from interviews with and documentary  evidence from personnel associated with a variety of governmental offices:  OUSD(I), DISCO, DOHA, other DOD adjudication facilities that make  clearance determinations for servicemembers and DOD civilians; DOD’s  Personnel Security Research Center; the Defense Security Service’s  Training Academy that offers adjudicator training; and OPM.  Nongovernmental organizations supplying information on conditions,  causes, and effects included officials representing two of OPM’s  investigations contractors and technology associations whose member  organizations require clearances for their industry personnel employees.  For the timeliness question, our analyses of conditions included a review  of computerized data abstracted from DOD’s Joint Personnel Adjudication  System (JPAS) and statistical reports on timeliness that OPM produced for  DOD. The abstract was for the population of 1,685 industry personnel  granted an initial top secret clearance and 574 industry personnel granted  a top secret clearance update by DISCO during January and February  2006. The clearance investigations for those 2,259 industry personnel were  started at various times prior to the adjudications. While we found  problems with the accuracy of some of the JPAS data, we determined they  were sufficiently reliable for the purposes of this report. DOD and OPM  also supplied timeliness statistics for other periods, levels of clearances,  types of personnel, and agencies to provide us with a broader context to  interpret the timeliness statistics that we computed from the database  abstract. We addressed the completeness question with a multiple-step  process. We (1) randomly selected 50 cases from the previously described  population of 1,685 initially cleared industry personnel, (2) obtained paper  files of the 50 investigative and adjudicative reports, (3) created a data  collection instrument using federal investigative standards and  adjudicative guidelines to standardize our data gathering, (4) sought  experts’ comments to refine our instrument and process, (5) coded data  from the paper files, (6) had a second team member independently verify  the information that another team member had coded, and (7) computed  statistics to indicate the numbers of investigative and adjudicative reports  with various types of missing documentation. In addition, two team  members attended OPM’s basic special agent training course to obtain an  understanding of the investigative requirements as promulgated by OPM,  and two other members of our team took about 40 hours of online  adjudications training. We performed our work from September 2005  through August 2006 in accordance with generally accepted government  auditing standards. Additional information on our scope and methodology  is presented in appendix I.
subsections: section_title: Background
paragraphs: As with servicemembers and federal workers, industry personnel must  obtain a security clearance to gain access to classified information, which  is categorized into three levels: top secret, secret, and confidential. The  level of classification denotes the degree of protection required for  information and the amount of damage that unauthorized disclosure could  reasonably be expected to cause to national defense or foreign relations.  For top secret information, the expected damage that unauthorized  disclosure could reasonably be expected to cause is “exceptionally grave  damage”; for secret information, it is “serious damage”; and for  confidential information, it is “damage.”
To ensure the trustworthiness, reliability, and character of personnel in  positions with access to classified information, DOD relies on a  multiphased personnel security clearance process. Figure 1 shows six  phases that could be involved in determining whether to grant an actual or  a potential job incumbent a clearance. The three phases shown in gray are  those that are most transparent to individuals requesting an initial  clearance. Such individuals may not have been aware that they  are allowed to apply for a clearance only if a contractor determines that  access is essential in the performance of tasks or services related to the  fulfillment of a classified contract (Phase 1),    have certain appeal rights if their clearance request is denied or their  clearance is subsequently revoked (Phase 5), and    may need to renew their clearance in the future if they occupy their  position for an extended period (Phase 6).
In the application-submission phase, if a position requires a clearance (as  has been determined in Phase 1), then the facility security officer must  request an investigation of the individual. The request could be the result  of needing to fill a new position for a recent contract, replacing an  employee in an existing position, renewing the clearance of an individual  who is due for clearance updating (Phase 6), or processing a request for a  future employee in advance of the hiring date. Once the requirement for a  security clearance is established, the industry employee completes a  personnel security questionnaire using OPM’s Electronic Questionnaires  for Investigations Processing (e-QIP) system, or a paper copy of the  standard form 86. After a review, the facility security officer submits the  questionnaire and other information such as fingerprints to OPM.
In the investigation stage, OPM or one of its contractors conducts the  actual investigation of the industry employee by using standards that were  established governmentwide in 1997. As table 1 shows, the type of  information gathered in an investigation depends on the level of clearance  needed and whether an investigation for an initial clearance or a  reinvestigation for a clearance update is being conducted. For either an  initial investigation or a reinvestigation for a confidential or secret  clearance, investigators gather much of the information electronically. For  a top secret clearance, investigators gather additional information that  requires much more time-consuming efforts, such as traveling, obtaining  police and court records, and arranging and conducting interviews. 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. After the investigation is complete, OPM forwards  a paper copy of the investigative report to DISCO for adjudication.
In the adjudication stage, DISCO or some other adjudication facility uses  the information from the investigative report to determine whether an  individual is eligible for a security clearance. For our May 2004 report, an  OUSD(I) official estimated that it took three times longer to adjudicate a  top secret clearance than it did to adjudicate a secret or confidential  clearance. If the report is determined to be a “clean” case—a case that  contains no or minimal potential security issues—the DISCO adjudicators  determine eligibility for a clearance. However, if the case is determined to  be an “issue” case—a case containing information that might disqualify an  individual for a clearance (e.g., serious foreign connections or drug- or  alcohol-related problems)—then DISCO forwards the case to DOHA  adjudicators for the clearance-eligibility decisions. Regardless of which  office renders the adjudication to approve, deny, or revoke eligibility for a  security clearance, DISCO issues the clearance-eligibility decision and  forwards the determination to the industrial contractor. All adjudications  are based on 13 federal adjudicative guidelines established  governmentwide in 1997 and implemented by DOD in 1998 (see app. II).  The President approved an update of the adjudication guidelines on  December 29, 2005. According to OMB, DOD should be using these  updated guidelines.
section_title: Determining Top Secret Clearances for Industry Personnel Averaged More than One Year and Government Statistics Did Not Portray All Delays
paragraphs: Industry personnel contracted to work for the federal government waited  more than one year on average to receive top secret security clearances,  and government statistics did not portray the full length of time it takes  many applicants to obtain a clearance. Industry personnel in the  population from which our sample was randomly selected waited on  average over one year for initial clearances and almost a year and a half  for clearance updates. The phase of the process between the time an  applicant submits his or her application and the time the investigation  actually begins averaged over 3 months, and government statistics did not  fully account for the time required to complete this phase. In addition, the  investigative phase for industry personnel was not timely, and government  statistics did not account for the full extent of the delay. Delays in the  clearance process may cost money and pose threats to national security.
subsections: section_title: Delays in the Application- Submission and Investigation Phases Are Caused by Many Factors
paragraphs: Industry personnel granted eligibility for top secret clearances from  DISCO in January and February 2006 waited an average of 446 days for  their initial clearance or 545 days for their clearance update. DISCO may,  however, have issued an interim clearance to some of these industry  personnel, which might have allowed them to begin classified work for  many contracts. Beginning in December 2006, IRTPA will require that 80  percent of all clearances—regardless of clearance level—be completed in  an average of 120 days. The government plan for improving the personnel  security clearance process provides quarterly goals for various types of  initial clearances. Since the completion of initial clearances is given  priority over completion of clearance updates, much of our discussion in  this section focuses on the timeliness of initial clearances.
subsections: section_title: Lengthy Application- Submission Phase Lacks Transparency
paragraphs: The application-submission phase of the clearance process took on  average 111 days for the initial clearances that DISCO adjudicated in  January and February 2006 (see table 2). The starting point for our  measurement of this phase was the date when the application was  submitted by the facility security officer. Our end point for this phase was  the date that OPM scheduled the investigation into its Personnel  Investigations Processing System (PIPS). We used this starting date  because the government can begin to incur an economic cost if an  industry employee cannot begin work on a classified contract because of  delays in obtaining a security clearance and this end date because OPM  currently uses this date as its start point for the next phase in the  clearance process. The governmentwide plan on improving the clearance  process noted that “investigation submission” (i.e., application- submission) be completed in 14 calendar days or less. Therefore, the 111  days taken for the application-submission phase took nearly 100 more  days on average than allocated.
Several factors contribute to the amount of time we observed in the  application-submission phase, including rejecting applications multiple  times, multiple completeness reviews, and manually entering data from  paper applications. For example, an April 2006 DOD Office of Inspector  General report cited instances where OPM rejected applications multiple  times due to inaccurate information. The security managers interviewed  for that report said it appeared that OPM did not review the entire  documents for all errors before returning them. Security managers at two  DOD locations noted that in some cases OPM had rejected the same  application submission three or four times for inaccurate information. The  cited inaccuracies included outdated references, telephone numbers, and  signatures, as well as incorrect zip codes. Another source of delay is the  multiple levels of review that are performed before the application is  accepted. Reviews of the clearance application might include the  corporate facility security officer, DISCO adjudicators, and OPM staff. A  third source of the delay in the application-submission phase is the time  that it takes OPM to key-enter data from paper applications. For April  2006, OPM’s Associate Director in charge of the investigations unit stated  that applications submitted on paper took an average of 14 days longer  than submissions through OPM’s electronic Questionnaires for  Investigations Processing (e-QIP). She also noted additional information  on e-QIP that could portend future timeliness improvements  governmentwide: in May 2006, over 221,000 investigations had been  requested through e-QIP by 50 agencies (up from 17,000 submissions by 27  agencies in June 2005), and a goal to reduce the rejection rate for e-QIP  applications from the current 9 percent to 5 percent. The gray portion of  table 2’s application-submission phase identifies some tasks that are not  currently included in the investigation phase of the clearance process but  which could be included in the investigation phase, depending on the  interpretation of what constitutes “receipt of the application for a security  clearance by an authorized investigative agency”—IRTPA’s start date for  the investigations phase.
section_title: Investigative Phase Took Longer Than the Goal Specified
paragraphs: Investigations for the initial top secret clearances of industry personnel  took an average of 286 days for DISCO cases adjudicated in January and  February 2006 (see table 2). During the same period, investigations for top  secret clearance updates took an average of 419 days, almost 1½ times as  long as the initial investigations. Compared to our findings, OPM reported  that the time required to complete initial investigations for top secret  clearances was much shorter when it analyzed governmentwide data for  April 2006. The newer data indicate that OPM completed the initial  investigations in 171 days. While some of that difference in investigation  times reported by GAO and OPM may be related to better productivity, a  later section of this report identifies other factors that could have  contributed to the difference. The shorter period of 171 days is less than  the 180 days provided as a goal in the governmentwide plan. But the  methods for computing the 171 days may not have included the total  average time required to complete an initial clearance.
Many factors impede the speed with which OPM can deliver investigative  reports to DISCO and other adjudication facilities. As we have previously  identified, DOD’s inability to accurately project the number of requests for  security clearances is a major impediment to investigative workload  planning and clearance timeliness. As we noted in 2004 when both OPM  and DOD were struggling to improve investigation timeliness, backlogged  investigations contributed to delays because most new requests for  investigations remain largely dormant until earlier requests are  completed. The governmentwide plan for improving the personnel  security clearance process also asserted that while the total number of  OPM federal and contract investigators was sufficient to meet the  timeliness requirements of the IRTPA, many of the investigative staff are  relatively inexperienced and do not perform at a full-performance level. In  May 2006, we noted that OPM reported progress in developing an overseas  presence to investigate leads overseas, but acknowledged it will take time  to fully meet the full demand for overseas investigative coverage. In May  2006, the Associate Director in charge of OPM’s investigations unit  indicated that her unit continues to have difficulty obtaining national,  state, and local records from third-party providers. Similarly,  representatives for contractors and their associations are concerned that  new investigative requirements like those in Homeland Security  Presidential Directive-12 could further slow responses to OPM’s requests  for information from national, state, and local agencies. Finally, more  requests for top secret clearances could slow OPM’s ability to meet the  IRTPA timeliness requirements, since investigations for that level of  clearance are estimated to take 10 times the number of staff hours as do  investigations for secret and confidential clearances.
section_title: DISCO Adjudications May Have Achieved the IRTPA Timeliness Requirement
paragraphs: DISCO adjudicators took an average of 39 days to grant initial clearance  eligibility to the industry personnel whose cases were decided in January  and February 2006 (see table 2). The measurement of this phase for our  analysis used the same start and stop dates that OPM uses in its reports,  starting on the date that OPM closed the report and continuing through the  date that DISCO adjudicators decided clearance eligibility. In December  2006, IRTPA will require that at least 80 percent of the adjudications be  completed within 30 days. As of June 2006, DISCO reported that it had  adjudicated 82 percent of its initial top secret clearances within 30 days. In  its report, DISCO excluded the time required to print and transfer  investigative reports from OPM to DISCO.
Two data reliability concerns make it difficult to interpret statistics for the  adjudication phase of the clearance process. First, the activities in the gray  section in the adjudication phase of table 2 show that the government’s  current procedures for measuring the time required for the adjudication  phase include tasks that occur before adjudicators actually receive the  investigative reports from OPM. Although the information that we  analyzed could not be used to determine how much time had elapsed  before DISCO received the investigative reports, DOD adjudication  officials recently estimated that these printing and transfer tasks had taken  2 to 3 weeks. OUSD(I) and adjudication officials said that inclusion of this  time in the adjudication phase holds adjudicators accountable for time  that is not currently in their control. They acknowledge that OPM has  offered faster electronic delivery of the investigative reports, but they  countered that they would need to then print the reports since the files are  not offered in an electronic format that would allow the adjudicators to  easily use the electronic information. The second data reliability problem  is DOD’s nonreporting of final dates of adjudication decisions to OPM.  While we had the dates that the clearance eligibility was determined for  our data, OPM officials have noted that DOD departmentwide reported  about 10 percent of its adjudication decisions back to OPM for August  2006. Although OPM reports this information as specified by the  government plan for improving the security clearance process, OPM  officials acknowledged that they have not enforced the need to report this  information. When asked about this issue, DOD officials indicated that  OPM would not accept a download of adjudication dates from JPAS that  DOD had offered to provide on compact discs. Since DOD represents  about 80 percent of the security clearances adjudicated by the federal  government, not including these data could make it appear as if  adjudication timeliness is different than it actually is.
section_title: Delays in Clearance Process Cost Money and Threaten National Security
paragraphs: In 2004, we outlined unnecessary costs and threats to national security  that result from delays in determining clearance eligibility. Those same  negative consequences apply today. Delays in completing initial security  clearances may have an economic impact on the costs of performing  classified work within or for the U.S. government. In a 1981 report, we  estimated that DOD’s investigative backlog of overdue clearances cost  nearly $1 billion per year in lost productivity. More than a decade later, a  Joint Security Commission report noted that the costs directly attributable  to investigative delays in fiscal year 1994 could have been as high as  several billion dollars because workers were unable to perform their jobs  while awaiting a clearance. While newer overall cost estimates are not  available, the underlying reasons—the delays in determining clearance  eligibility that we documented in this report—still exist today.
The impact of delays in completing initial clearances affects industry, and  therefore affects the U.S. government, which is funding the work that  requires the clearances. In a May 2006 congressional hearing, a  representative for a technology association testified that retaining  qualified personnel is resulting in salary premiums as high as 25 percent  for current clearance holders. The association representative went on to  note that such premiums raise costs to industry, which in turn passes on  the costs to the government and taxpayers. In 2004, representatives of a  company with $1 billion per year in sales stated that their company offered  $10,000 bonuses to its employees for each person recruited who already  had a security clearance. In cases where recruits left for the company in  question, their former companies faced the possibility of having to back- fill a position, as well as possibly settling for a lower level of contract  performance while a new employee was found, obtained a clearance, and  learned the former employee’s job. Also, industry representatives  discussed instances where their companies gave hiring preferences to  cleared personnel who could do the job but were less qualified than others  who did not possess a clearance. The chair of the interagency Personnel  Security Working Group at the time of our 2004 report noted that a  company might hire an employee and begin paying that individual, but not  assign any work to the individual until a clearance is obtained. Also, the  head of the interagency group noted that commands, agencies, and  industry might incur lost-opportunity costs if the individual chooses to  work somewhere else rather than wait to get the clearance before  beginning work.
The negative effects of the failure to deliver timely determinations of  initial clearance eligibility extend beyond industry personnel to  servicemembers and federal employees. An April 2006 DOD Office of  Inspector General report provided examples to illustrate how delays in the  clearance process can result in negative consequences such as  nonproductive time waiting for a clearance. That report noted that delays  have caused students at military training facilities to remain in a holdover  status while waiting for a final clearance to complete training courses,  graduate, or deploy. In addition, students without a final clearance may  have their duty stations changed, which impacts their ability to fully  support DOD missions for which they were trained.
Delays in completing clearance updates can have serious but different  negative consequences than those stemming from delays in completing  initial clearance-eligibility determinations. Delays in completing clearance  updates may lead to a heightened risk of national security breaches. Such  breaches involve the unauthorized disclosure of classified information,  which can have effects that range from exceptionally grave damage to  national security in the case of top secret information to damage in the  case of confidential information. In 1999, the Joint Security Commission  reported that delays in initiating investigations for clearance updates  create risks to national security because the longer individuals hold  clearances the more likely they are to be working with critical information  systems.
section_title: OPM’s Timeliness Reporting Does Not Convey Full Magnitude of Delays
paragraphs: The timeliness statistics that OPM provided in the recent congressional  hearings do not convey the full magnitude of the investigations-related  delays facing the government. In her May 17, 2006, congressional  testimony statement, the Associate Director in charge of OPM’s  investigations unit said that OPM continued to make “significant progress”  in reducing the amount of time needed to complete initial security  clearance investigations. She supported her statement with statistics that  showed OPM’s initial investigations for top secret clearances  governmentwide averaged 284 days in June 2005 and decreased to 171  days in April 2006 (see table 3). When we converted these two timeliness  statistics to a percentage, we found that the average time to complete an  investigation for an initial top secret clearance in April 2006 was about 60  percent of what it had been in June 2005. We also calculated the  percentage change for the numbers of investigations completed in the  same 2 months and found that OPM had completed about 68 percent  (5,751 versus 8,430) as many initial investigations for top secret clearances  in April 2006 as it did in June 2005. Her statement went on to mention that  another problem was developing—the inventory of pending investigations  was increasing because of difficulty obtaining information from third-party  providers.
The testimony statement did not provide timeliness statistics for the  investigations that are conducted for clearance updates, but that type of  investigation probably had longer completion times than did the initial  investigations. Our previously reviewed statistics on industry personnel  (see table 2) indicated that clearance update investigations took about 1½  times as long as the initial investigations. The absence of information on  clearance-update investigations from the OPM’s Associate Director’s  testimony statement may be partially explained by the higher priority that  OMB and OPM have placed on completing initial clearances so that  individuals who have not previously had clearances can begin classified  work sooner. At the same time, the absence of information on clearance- update investigations does not provide all stakeholders—Congress,  agencies, contractors attempting to fulfill their contracts, and employees  awaiting their clearances—with a complete picture of clearance delays.  We have noted in the past that focusing on completing initial clearance  investigations could negatively affect the completion of clearance-update  investigations and thereby increase the risk of unauthorized disclosure of  classified information.
The testimony statement did not indicate whether or not the statistics on  complete investigations included a type of incomplete investigation that  OPM sometimes treats as being complete. In our February 2004 report, we  noted that OPM’s issuance of “closed pending” investigations— investigative reports sent to adjudication facilities without one or more  types of source data required by the federal investigative standards— causes ambiguity in defining and accurately estimating the backlog of  overdue investigations. In our February 2004 report, we also noted that  cases that are closed pending the provision of additional information  should continue to be tracked separately in the investigations phase of the  clearance process. According to recently released OPM data, between  February 20, 2005, and July 1, 2006, the number of initial top secret  clearance investigative reports that were closed pending the provision of  additional information increased from 14,841 to 18,849, a 27 percent  increase. DISCO officials and representatives from some other DOD  adjudication facilities have indicated that they will not adjudicate closed  pending cases since critical information is missing. OPM, however, has  stated that other federal agencies review the investigative reports from  closed pending cases and may determine that they have enough  information for adjudication. Combining partially completed investigations  with fully completed investigations overstates how quickly OPM is  supplying adjudication facilities with the information they request to make  their clearance-eligibility determinations.
OPM told us that it does not continue counting the time when agencies  return investigative reports for rework because they were in some way  deficient. Instead, OPM begins the count of days in the investigative phase  anew. OPM says that approximately 1 to 2 percent of its investigations are  reopened for such work. OPM has indicated that system problems prevent  them from continuing to monitor these returned investigations as a  continuation of the prior investigations. By not fully capturing all  investigative time—including the review time which occurred at the  adjudication facility and resulted in returning a report—OPM is  undercounting the number of days that it takes to conduct an  investigation.
Finally, our analysis of OPM’s quarterly reports, which are provided to  OMB and Congress, revealed computational errors. For example, using  information from such reports, we found that the number of adjudications  completed in the second quarter of 2006 was off by about 12,000 cases.  One reason for the errors was mistakes in the programs used to extract  the data from OPM’s database, rather than the use of a documented and  verified computer program that can be used again as data are updated.  Without complete and accurate data and analyses, Congress, OMB, and  others do not have full visibility over the timeliness of the clearance  process.
section_title: OPM Delivered Incomplete Investigative Reports and DISCO Adjudicated Cases Did Not Document All Clearance- determination Considerations
paragraphs: OPM provided incomplete investigative reports to DOD adjudicators,  which they used to determine top secret clearance eligibility. Almost all  (47 of 50) of the sampled investigative reports we reviewed were  incomplete based on requirements in the federal investigative standards.  In addition, DISCO adjudicators granted clearance eligibility without  requesting additional information for any of the incomplete investigative  reports and did not document that they considered some adjudicative  guidelines when adverse information was present in some reports.  Granting clearances based on incomplete investigative reports increases  risks to national security. In addition, use of incomplete investigative  reports and not fully documenting adjudicative considerations may  undermine the government’s efforts to increase the acceptance of security  clearances granted by other federal agencies.
subsections: section_title: Almost All of the Sampled Investigative Reports Were Incomplete
paragraphs: In our review of 50 initial investigations randomly sampled from the  population used in our timeliness analyses, we found that almost all (47 of  50) of the investigative reports were missing documentation required by  the federal investigative standards. The missing data were of two general  types: (1) the absence of documentation showing that an investigator  gathered the prescribed information in each of the applicable 13  investigative areas and included requisite forms in the investigative report,  and (2) information to help resolve issues (such as conflicting information  on indebtedness) that were raised in other parts of the investigative  report. The requirements for gathering these types of information were  identified in federal investigative standards published about a decade  ago. We categorized an investigative area as incomplete if the  investigative report did not contain all of the required documentation for  that area or issue resolution. For example, we categorized the employment  area as incomplete if investigators did not document a check of the  subject’s employee personnel file or the required number of interviews of  employment references such as supervisors and coworkers.
At least half of the 50 reports that we examined did not contain the  required documentation in three investigative areas: residence,  employment, and education (see fig. 2). In addition, many investigative  reports contained multiple deficiencies within each of these areas. For  example, multiple deficiencies might be present in the residence area  because investigators did not document a rental record check and an  interview with a neighborhood reference.
Looking at the data for figure 2 in a different way shows that three of every  five reports that we reviewed had at least three investigative areas that did  not have all of the prescribed documentation. Thirty-eight of the 50  investigative reports had two to four investigative areas with at least one  piece of missing documentation (see fig. 3).
The following examples illustrate some of the types of documentation  missing from the investigative reports that we reviewed. When we  discussed our findings for these investigative reports with OPM Quality  Management officials, they agreed that the OPM investigators should have  included documentation in the identified investigative areas.
Residence, social, and employment documentation were missing. One  investigative report did not have documentation on all of the required  residence interviews or to show they checked rental records at two of the  subjects’ residences. In addition, it contained no information from  required investigator-developed social references, but information from  interviews with two subject-identified social references was in the report.  Federal investigative standards require investigators to interview at least  two of the subject-identified social references and two additional social  references that the investigator develops during the course of the  investigation. Finally, investigators documented performing only 3 of the  10 employment interviews that would be required for the subject’s five  jobs covered by the investigative scope.
Residence, social, and employment documentation were missing. An  investigative report on a DOD industry employee did not contain  documentation on interviews with any neighborhood references where the  subject had resided for 10 years. Similarly, the report contained interview  documentation from one subject-identified but no investigator-developed  social reference. Of the eight employment reference interviews required by  federal standards for this investigative report, there was documentation  that three were performed.
Spouse national record documentation was missing. In another  investigative report, required documentation for four national agency  record checks of the subject’s cohabitant of 35 years was missing. The  four types of missing checks were the Federal Bureau of Investigation  name and fingerprints, OPM’s Security/Suitability Investigations Index,  and DOD’s Spouse Defense Clearance and Investigations Index.
Although federal standards indicate that investigations may be expanded  as necessary to resolve issues, according to OPM, (1) issue resolution is a  standard part of all initial investigations and periodic reinvestigations for  top secret clearances and (2) all issues developed during the course of an  investigation should be fully resolved in the final investigative report  provided to DOD. We found a total of 36 unresolved issues in 27 of the  investigative reports. The three investigative areas with the most  unresolved issues were financial consideration, foreign influence, and  personal conduct (see fig. 4).
The following examples highlight investigative areas that lacked the  documentation needed to resolve an issue. When we reviewed these  investigative reports with OPM Quality Management officials, they agreed  that the investigators should have included documentation to resolve the  issues.
Personal conduct and financial issues were unresolved. One investigative  report did not contain documentation of the resolution of possible  extramarital affairs and financial delinquency. During the course of the  investigation, the subject reported having extramarital affairs; however,  there was no documentation to show that these affairs had been  investigated further. Also, the subject’s clearance application indicated  cohabitation with an individual with whom the subject had previously had  a romantic relationship, but there was no documentation that record  checks were performed on the cohabitant. Moreover, information in the  investigative report indicated that the subject defaulted on a loan with a  balance of several thousand dollars; however, no other documentation  suggested that this issue was explored further.
Foreign influence issues were unresolved. The clearance application  showed that the subject had traveled to an Asian country to visit family.  However, in the subject interview, the subject reported not knowing the  names of the family members or the city in which one relative lived. There  was no documentation in other parts of the investigative report of a  follow-up discussion with the subject about this issue.
Financial issues were unresolved. An industry employee indicated “no” in  his clearance application when asked if during the last 7 years he had a  lien placed against his property for failing to pay taxes or other debt, but  information in another part of the investigative report indicated that a tax  lien in the tens of thousands of dollars had been placed against his  property. The investigative report did not have additional information to  indicate whether or not investigators asked the subject about the omission  on the application or the tax lien itself.
Although we found that the interview narratives in some of the 50 OPM  investigative reports were limited in content, we did not identify them as  being deficient for the purposes of our statistical analysis because such an  evaluation would have required a subjective assessment that we were not  willing to make. For example, in our assessment of the presence or  absence of documentation, we found a 35-word narrative for a subject  interview of a naturalized citizen from an Asian country. It stated only that  the subject did not have any foreign contacts in his birth country and that  he spent his time with family and participated in sports. Nevertheless,  others with more adjudicative expertise voiced concern about the issue of  documentation adequacy. At their monthly meeting in April 2006, top  officials representing DOD’s adjudication facilities were in agreement that  OPM-provided investigative summaries had been inadequate. The OPM  Investigator’s Handbook provides guidance that directs investigators to be  brief in the interview narratives but not to sacrifice content. Narrative  documentation is required for subject interviews and all interviews with  references contacted in the investigation, including neighbors, character  references, and coworkers.
The Associate Director of OPM’s investigations unit and her Quality  Management officials cited the inexperience of the investigative workforce  as one of the possible causes for the incomplete investigative reports we  reviewed. This inexperience is due to the fact that OPM has rapidly  increased the size of the investigative workforce. In December 2003, GAO  estimated that OPM and DOD had around 4,200 full-time equivalent  investigative personnel. In May 2006, the Associate Director said that OPM  had over 8,600 employees. The Associate Director also indicated that  variations in the training provided to federal and contractor investigative  staff could be another reason for the incompleteness. These variations can  occur since each contract investigative company is responsible for  developing the training course for its employees. She, however, added that  OPM (1) publishes the Investigator’s Handbook that provides guidance on  how to conduct an investigation and forms the basis for the training, (2)  approves the training curriculum for each contractor, and (3) occasionally  monitors actual training sessions.
The Associate Director also noted that she had little indication from her  customers—adjudicators—that the investigative reports had problems  since adjudicative facilities were returning 1 to 2 percent of the reports for  rework. In our November 2005 testimony evaluating the government plan  for improving the personnel security clearance process, we noted that the  number of investigations returned for rework is not by itself a valid  indicator of the quality of investigative work because adjudication officials  said they were reluctant to return incomplete investigations in anticipation  of further delays. We went on to say in November 2005 that regardless of  whether that metric remains a part of the government plan, developers of  the plan may want to consider adding other indicators of the quality of  investigations. When we asked if OMB and OPM had made changes to the  government plan to address quality-measurement and other shortcomings  that we had identified in our November 2005 testimony, the Associate  Director said the plan had not been modified to address our concerns but  implementation of the plan was continuing.
OPM’s Associate Director outlined new quality control procedures that  were put in place after the investigations that we reviewed were  completed. Among other things, OPM has a new contractor responsible for  reviewing the quality of its investigative reports, a new organizational  structure for its quality control group, and new quality control processes.  After describing these changes, the Associate Director acknowledged that  it will take time before the positive effects from the changes will be fully  realized.
section_title: DISCO Adjudicators Granted Top Secret Clearance Eligibility for Cases with Missing Information
paragraphs: DISCO adjudicators granted top secret clearance eligibility for the 27  industry personnel whose investigative reports contained unresolved  issues without requesting additional information or documenting in the  adjudicative report that the information was missing. Furthermore, in 17  cases, adjudicators did not document consideration of guidelines. In  making clearance-eligibility determinations, the federal guidelines require  adjudicators to consider (1) guidelines covering 13 specific areas such as  foreign influence and financial considerations, (2) adverse conditions or  conduct that could raise a security concern and factors that might mitigate  (alleviate) the condition for each guideline, and (3) general factors related  to the whole person. (See app. II for additional details on these three types  of adjudicative considerations.) According to a DISCO official, DISCO and  other DOD adjudicators are to record information relevant to each of their  eligibility determinations in JPAS. They do this by selecting applicable  guidelines and mitigating factors from prelisted responses and may type  up to 3,000 characters of additional information.
DISCO adjudicators granted clearance eligibility for 27 industry personnel  whose investigative reports did not contain the required documentation to  resolve issues raised in other parts of the investigative reports (see fig. 4).  The corresponding adjudicative reports for the 27 industry personnel did  not contain documentation showing that adjudicators had identified the  information as missing or that they attempted to return the investigative  reports to obtain the information required by the federal adjudicative  guidelines. The following are examples of unresolved issues that we found  in adjudicative and investigative reports and later discussed with DISCO  officials, including administrators and adjudicators. For both examples,  the DISCO officials agreed that additional information should have been  obtained to resolve the issues before the industry personnel were granted  top secret clearances.
Information to resolve a foreign influence issue was missing. A state-level  record check on an industry employee indicated that the subject was part  owner of a foreign-owned corporation. Although the DISCO adjudicator  applied the foreign influence guideline for the subject’s foreign travel and  mitigated that foreign influence issue, there was no documentation in the  adjudicative report to acknowledge or mitigate the foreign-owned  business.
Information to resolve a foreign influence issue was missing. An industry  employee reported overseas employment on their application, but the  subjects adjudicative and investigative reports did not contain other  documentation of the 6 years (all within the scope of the investigation)  that they spent working for a DOD contractor in two European countries.  For example, the subject interview documentation did not indicate  whether the subject’s relationships with foreign nationals had been  addressed. The adjudicative and investigative reports did not document  verification of the subject’s residence and interviews with overseas social  references. Furthermore, the adjudicative report did not indicate that the  foreign influence guideline was considered as part of the clearance  determination.
When asked why the adjudicators did not provide the required  documentation in JPAS, the DISCO officials said that its adjudicators  review the investigative reports for sufficient documentation to resolve  issues and will ask OPM to reopen a case if they do not have enough  information to reach an eligibility determination. The DISCO officials and  Defense Security Service Academy personnel who teach adjudicator  training courses cited risk management as a reason that clearance  determinations are made without full documentation. They said that  adjudicators make judgment calls about the amount of risk associated  with each case by weighing a variety of past and present, favorable and  unfavorable information about the person to reach an eligibility  determination. The trainers also said that adjudicators understand that  investigators may not be able to obtain all of the information needed to  resolve all issues. Notably, DISCO and DOHA officials told us that DISCO  adjudicators determine eligibility for cases with few or no issues and that  DOHA adjudicates cases with potentially more serious issues.
Seventeen of the 50 adjudicative reports were missing documentation on a  total of 22 guidelines for which issues were present in the investigative  reports. The guideline documentation missing most often was for foreign  influence, financial considerations, alcohol consumption, and personal  conduct issues (see fig. 5). We, like DISCO adjudicators, used the  Adjudicative Desk Reference and DOD’s Decision Logic Table to help  determine whether or not documentation of a guideline was needed. An  example of the lack of documentation shown in figure 5 was when DISCO  adjudicators did not record consideration of the personal conduct  guideline despite a subject’s involvement in an automobile accident while  driving with a suspended driver’s license, no auto insurance, and an  expired car license.
DISCO officials stated that procedural changes associated with JPAS  implementation contributed to the missing documentation on guidelines.  DISCO began using JPAS in February 2003, and it became the official  system for all DOD adjudications in February 2005. Before February 2005,  DISCO adjudicators were not required to document the consideration of a  guideline issue unless adverse information could disqualify an individual  from being granted clearance eligibility. After JPAS implementation,  DISCO adjudicators were trained to document in JPAS their rationale for  the clearance determination and the adverse information from the  investigative report, regardless of whether or not an adjudicative guideline  issue could disqualify an individual from obtaining a clearance. The  administrators also attributed the missing guideline documentation to a  few adjudicators attempting to produce more adjudication determinations.
section_title: Delivery and Use of Incomplete Investigations Increase Risks to National Security and Reciprocity
paragraphs: Decisions to grant clearances based on incomplete investigations increase  risks to national security because individuals can gain access to classified  information without being vetted against the full federal standards and  guidelines. Although there is no guarantee that individuals granted  clearances based on complete investigations will not engage in espionage  activities, complete investigations are a critical first step in ensuring that  those granted access to classified information can be trusted to safeguard  it.
Adjudicators’ reviews of incomplete investigative reports can have  negative economic consequences for adjudication facilities, regardless of  whether the incomplete report is (1) an inadvertent failure by OPM to  detect the missing information during its quality control procedures or (2)  a conscious decision to forward a closed pending case that OPM knows is  not complete. Specifically, adjudication facilities must use adjudicator  time to review cases more than once and then use additional time to  document problems with the incomplete investigative reports. Conversely,  an adjudicative review of incomplete cases could have the benefit of  alerting adjudicators to negative information on a person who has been  granted an interim initial clearance so that the adjudication facility could  determine whether that interim clearance should be revoked pending a full  investigative report.
Incomplete investigations and adjudications undermine the government’s  efforts to move toward greater clearance and access reciprocity. An  interagency working group, the Security Clearance Oversight Steering  Committee, has noted that agencies are reluctant to be accountable for  poor quality investigations and/or adjudications conducted by other  agencies or organizations. To achieve fuller reciprocity, clearance-granting  agencies need to have confidence in the quality of the clearance process.  Without full documentation of investigative actions, information obtained,  and adjudicative decisions, agencies could continue to require duplicative  investigations and adjudications.
section_title: Conclusions
paragraphs: Incomplete timeliness data limit the visibility of stakeholders and decision  makers in their efforts to address long-standing delays in the personnel  security clearance process. For example, not accounting for all of the time  that is required when industry personnel submit an application multiple  times before it is accepted limits the government’s ability to accurately  monitor the time required for each step in the application-submission  phase and identify positive steps that facility security officers, DISCO  adjudicators, OPM investigative staff, and other stakeholders can take to  speed the process. Similarly, OPM’s procedure of restarting the  measurement of investigation time for the 1 to 2 percent of investigative  reports that are sent back for quality control reasons does not hold OPM  fully accountable for total investigative time when deficient products are  delivered to its customers. In fact, restarting the time measurement for  reworked investigations could positively affect OPM’s statistics if the  reworked sections of the investigation take less time than did the earlier  effort to complete the large portion of the investigative report.  Information-technology-related problems are another area where needless  delays are being experienced. Failure to fully utilize e-QIP adds about 2  weeks to the application-submission time, and the government must pay to  have information key-entered into OPM’s investigative database. Likewise,  an estimated 2 to 3 weeks are added to the adjudication phase because of  the need to print and ship investigative reports to DISCO and other  adjudication facilities. These and other reasons for delays show the  fragmented approach that the government has taken to addressing the  clearance problems. In November 2005, we were optimistic that the  government plan for improving the clearance process prepared under the  direction of OMB’s Deputy Director for Management would be a living  document that would provide the strategic vision for correcting long- standing problems in the personnel security clearance process. However,  OPM recently told us that the plan has not been modified in the 9 months  since we labeled it as an important step forward but identified numerous  shortcomings that should be addressed to make it a more powerful vehicle  for change.
While eliminating delays in the clearance process is an important goal, the  government cannot afford to achieve that goal by providing investigative  and adjudicative reports that are incomplete in key areas required by  federal investigative standards and adjudicative guidelines. The lack of full  reciprocity of clearances is an outgrowth of agencies’ concerns that other  agencies may have granted clearances based on inadequate investigations  and adjudications. OMB’s Deputy Director of Management has convened  an interagency committee to address this problem and has taken steps to  move agencies toward greater reciprocity. The findings in this report may  suggest to some security managers that there is at least some evidence to  support agencies’ concerns about the risks that may come from accepting  the clearances issued by other federal agencies. Readers are reminded,  however, that our review and the analyses presented here looked at only  one aspect of quality—completeness of reports. We could not address  whether the information contained in the investigative reports we  reviewed was adequate for determining clearance eligibility and whether  all 50 of the industry personnel should have been granted clearances. Such  judgments are best left to fully trained, experienced adjudicators. Still, our  findings do raise questions about (1) the adequacy of the procedures that  OPM used to ensure quality before sending its investigative reports to its  customers and (2) DISCO’s procedures for reviewing the quality of the  clearance determinations made by its adjudicators when information was  missing from the investigative reports or decisions were not fully  documented in JPAS. Furthermore, as we pointed out in November 2005,  the almost total absence of quality metrics in the governmentwide plan for  improving the clearance process hinders Congress’s oversight of these  important issues. Finally, the missing documentation could have longer  term negative effects such as requiring future investigators and  adjudicators to obtain the documentation missing from current reviews  when it is time to update the clearances currently being issued.
section_title: Recommendations for Executive Action
paragraphs: To improve the timeliness of the processes used to determine whether or  not industry personnel are eligible for a top secret clearance, we are  making the following recommendations to the Director of the Office of  Management and Budget to direct the Deputy Director for Management, in  his oversight role of the governmentwide clearance process, to take the  following actions:    Direct OPM and DOD to fully measure and report all of the time that  transpires between when the application is initially received by the federal  government to when the clearance-eligibility determination has been  provided to the customer. Inherent in this recommendation to increase  transparency is the need to provide all stakeholders (including facility  security officers, federal and contract investigators, and adjudicators)  information about each of their steps within the clearances phases so that  each can develop goals and implement actions to minimize delays.
Establish an interagency working group to identify and implement  solutions for investigative and adjudicative information technology  problems—such as some parts of DOD continuing to submit paper copies  of the clearance application, or inefficiencies—such as the continued  distribution of paper investigative reports—that have resulted in clearance  delays.
To improve the completeness of the documentation for the processes used  to determine whether or not industry personnel are eligible for a top  secret clearance and to decrease future concerns about the reciprocal  acceptance of clearances issued by other agencies, we are recommending  that the Director of the Office of Management and Budget direct the  Deputy Director for Management, in his oversight role of the  governmentwide clearance process, to take the following actions:    Require OPM and DOD to (1) submit to the Deputy Director their  procedures for eliminating the deficiencies that we identified in their  investigative and adjudicative documentation and (2) develop and report  metrics on completeness and other measures of quality that will address  the effectiveness of the new procedures.
Update the government strategic plan for improving the clearance process  to address, among other things, the weaknesses that we identified in the  November 2005 version of the plan as well as the timeliness and  incompleteness issues identified in this report, and widely distribute it so  that all stakeholders can work toward the goals that they can positively  impact.
Issue guidance that clarifies when, if ever, adjudicators may use  incomplete investigative reports—closed pending and inadvertently  incomplete cases—as the basis for granting clearance eligibility.
section_title: Agency Comments
paragraphs: We received agency comments from OMB, DOD, and OPM (see apps. III,  IV, and V, respectively). In addition, OMB and OPM provided separate  technical comments which we incorporated in the final report, as  appropriate.
subsections: section_title: Office of Management and Budget
paragraphs: In his comments to our report, OMB’s Deputy Director for Management  did not take exception to any of our recommendations. Among other  things, he noted his agreement with our report’s conclusion that agencies  must identify and implement new investigative and adjudicative solutions  to improve the quality and timeliness of background investigations. The  Deputy Director stated that National Security Council’s Security Clearance  Working Group had begun to explore ways to identify and implement such  improvements. He also said that the quality of the investigations and  adjudications are of paramount concern and that he would ask the  National Security Council’s Personnel Security Working Group to  determine when, if ever, an adjudicator may use incomplete investigative  reports to determine whether to grant a security clearance.
section_title: Department of Defense
paragraphs: Although our recommendations were not directed to DOD, the Deputy  Under Secretary of Defense (Counterintelligence and Security) noted his  concurrence with our recommendations. The Deputy Under Secretary also  discussed the use of incomplete cases as the basis for adjudication. He  maintained that when the unresolved issues appear to be of minor  importance, a risk management adjudication may be prudent. After noting  that patchwork fixes will not solve the fundamental problem—”the current  process takes too long, costs too much, and leaves us with a product of  uncertain quality”—the Deputy Under Secretary reported that DOD is  working on a new process.
section_title: Office of Personnel Management
paragraphs: In her written comments, OPM’s Director stated that she fully supported  the intent of our report but expressed concern that we had based our  findings upon a number of inaccurate facts. We disagree. To address the  Director’s concerns, we grouped her concerns into four general categories  as discussed below.
The Director stated that a fair comparison cannot be made between PIPS  (OPM’s investigative database) and JPAS (DOD’s clearance database that  also includes investigative timeliness data). As our scope and methodology  section makes clear, we did report information from OPM and DOD  databases, but the focus of our report was not a comparison of databases.  While we did present timeliness findings based on the two databases, we  did not perform comparisons—a condition that would have required us to  report statistics on the same population for the same time period. Instead,  our draft report clearly noted when we were supplementing our findings  from the DOD database with more recent statistics from OPM. We also  noted that the OPM findings were governmentwide. Therefore, we are  puzzled by the Director’s comment since we supplied the additional OPM- provided statistics in our efforts to present a balanced view and reflect  OPM’s statements that investigation timeliness had improved. The  Director’s later statement that a fair comparison cannot be made between  the data in the two systems is troubling because underpinning effective  oversight is the prerequisite for reliable data. Regardless of whose data are  used, the two databases should produce timeliness statistics that agree  and cover the full periods that IRTPA require to be monitored: total  clearance process, investigations, and adjudications.
The Director took exception to our report’s assertion that stakeholders  and decision makers are limited in their ability to address delays in the  security clearance process because of incomplete timeliness data. She  stated that OPM feels stakeholders and decision makers have the most  comprehensive data possible to understand and address the delays in the  security clearance process. At the same time, other parts of her comments  noted deficiencies in OPM’s timeliness data. For example, she noted that  OPM does “not account for the timeliness of multiple submissions” [of  applications], and that OPM only measures “timeliness from beginning to  the point where OPM has completed all items under our direct control via  the Closed Pending process.” We stand behind our assertion that OPM has  incomplete timeliness data, and we believe the Director’s admissions  about the limitations of the OPM data reinforce the empirical basis of our  assertion. The evidence supplied in our draft report further contradicts the  Director’s assertion that stakeholders and decision makers have the most  comprehensive data possible. Our approach for investigating timeliness  and completeness is fully described in our scope and methodology,  including the specific steps that we took. For example, we sent written  questions and verbally inquired with OPM staff about whether OPM  tracked timeliness for certain situations, and the staff’s written and verbal  answers to those questions indicated that the agency does not measure the  timeliness of situations such as multiple submissions and the full period  required to conduct an investigation when the investigative report is  returned because of quality problems. IRTPA did not identify situations  that could be excluded from mandated timeliness assessments. Therefore,  we stand by our conclusion that without fully accounting for the total time  needed to complete the clearance process, OMB and Congress will not be  able to accurately determine whether agencies have met future IRTPA  requirements.
Concerning our findings that initial clearances took 446 days and  clearance updates took 545 days, the director noted that a sample of  current cases would likely show a marked improvement in consistency  and would reflect the many process improvements that have been put in  place since the time of transfer. Also, she indicated that some of the  problems that we reported were the result of transferred staff and cases.  We agree that it is possible that different findings might be obtained if a  more recent population were examined today. However, the population  that we examined represented the most up-to-date information available  when we began our timeliness analyses. With regard to the Director’s  statement that some of the problems were caused by the transfer of  investigative functions and personnel from DOD, OPM had 2 years to  prepare for the transfer between the announced transfer agreement in  February 2003 and its occurrence in February 2005. In addition, 47 of the  50 investigative reports that we reviewed were missing documentation  even though OPM has quality control procedures for reviewing the reports  before they are sent to DOD.
Lastly, the Director indicated that our report discounts the government’s  efforts to correct clearance problems, like the impact of IRTPA and the  government’s Plan for Improving the Personnel Security Clearance  Process. In addition, the Director wrote that the draft report did not  address the effects of the backlog and agencies’ inaccurate projections of  investigations workload. To the contrary, our draft report discussed each  of these issues and we believe the report presents a balanced assessment  of programs—identifying problems, discussing ongoing efforts to correct  situations, and helping the reader understand the context within which a  program functions. For example, the introduction discussed IRTPA, the  development of the plan, additional actions that were coordinated through  OMB’s Deputy Director for Management, and the transfer of DOD’s  investigative function to OPM. Similarly, we noted in the investigation- completeness section that OPM has increased its investigative workforce  in recent years. Our draft report also identified both concerns as factors  that impede the speed with which OPM can deliver investigative reports.
After careful consideration of the OPM Director’s concerns, we continue  to believe our findings and conclusions have merit.
As arranged with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from the  date of this report. At that time, we will send copies of this report to  interested congressional members: the Director of the Office of  Management and Budget; the Secretary of Defense; and the Director of the  Office of Personnel Management. We will also make copies available to  others upon request. In addition, the report will be available at no charge  on GAO’s Web site at http://www.gao.gov.
If you or other members have any additional questions about DOD’s  personnel security program, please contact me at (202) 512-5559 or  stewartd@gao.gov. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this  correspondence. GAO staff who made major contributions to the  correspondence are listed in appendix VI.
section_title: Appendix I: Scope and Methodology
paragraphs: The scope of our work emphasized the analysis of information on top  secret clearances for industry personnel. Earlier in this report, table 1  showed that all of the investigative information needed to determine  eligibility for a secret or confidential clearance is also required as part of  the investigative report considered when determining eligibility for a top  secret clearance. In addition, examining the timeliness and completeness  of documentation for top secret clearances focused our efforts on a level  of clearance where greater damage could occur through the unauthorized  disclosure of classified information. Our examination of clearance  information for industry personnel continued a line of research discussed  in our report issued in May 2004. With about 34 percent of its 2.5 million  clearances held by industry personnel who are performing contract work  for the Department of Defense (DOD) and 23 other agencies, this segment  of the workforce is playing an increasingly larger role in national security.
subsections: section_title: Methodology
paragraphs: To examine the timeliness of the processes used to determine whether or  not industry personnel are eligible for a top secret clearance, we reviewed  various documents, including laws and executive orders, DOD security  clearance policies, Office of Personnel Management (OPM) policies, and  the government plan for improving the security clearance process. These  sources provided the criteria that we used in our analyses, as well as  insights into possible causes for and effects of the delays in obtaining  timely clearances. We also reviewed clearance-related reports issued by  organizations such as GAO, DOD’s Office of Inspector General, and DOD’s  Personnel Security Research Center. We interviewed headquarters policy  and program officials from DOD’s Office of the Under Secretary of  Defense for Intelligence  and OPM and obtained and evaluated  additional documentation from those officials. In addition, representatives  from the organizations shown in table 4 provided additional interview and  documentary evidence that we also evaluated. A major focus of our  timeliness examination included our analysis of computerized data  abstracted from the Joint Personnel Adjudications System (JPAS) and  statistical reports on timeliness that OPM produced for DOD. We  calculated the number of days required for each case for three phases of  the process and the total process. Missing dates for the start or completion  dates for a phase prevented the calculation for some cases. Also, we  eliminated some dates for the phases when the start date was  chronologically later than the end date. As a result, the number of  applicable cases varies for each calculation. The abstract was for the  population of 1,685 industry personnel granted initial top secret clearances  and 574 industry personnel granted top secret clearance updates by the  Defense Industrial Security Clearance Office (DISCO) during January and  February 2006. The application-submission and investigation phases of the  clearance process for those 2,259 industry personnel were started at  various times prior to the final adjudication determinations. We assessed  the reliability of the JPAS data by (1) performing electronic testing of  required data elements, (2) reviewing existing information about the data  and the system that produced them, and (3) interviewing agency officials  knowledgeable about the data. While we found problems with the  accuracy of some of the JPAS data, we determined they were sufficiently  reliable for selecting a sample of cases for our review and for calculating  average days for the clearance process. DOD and OPM also provided  timeliness statistics for other time periods, levels of clearances, types of  personnel, and other federal agencies to provide us with a broader context  to interpret the timeliness statistics that we extracted from the DISCO  database abstract.
To examine the completeness of the documentation of the processes used  to determine whether or not industry personnel are eligible for a top  secret clearance, we used the sources identified above to answer the  timeliness question concerning: laws, executive orders, policies, reports,  and materials and testimonial evidence provided by the organizations  listed in table 4. The sources and materials provided us with an  understanding of the criteria for evaluating whether prescribed  information was present in or absent from investigative and adjudicative  reports used in the clearance process. Members of the GAO team attended  OPM’s basic special agent training course for 3 weeks to gain a greater  understanding of investigative procedures and requirements and  participated in the Defense Security Service Academy’s online basic  adjudicator training to learn more about adjudicative procedures and  requirements. Following the training, we began a multiple-step process to  review and analyze the investigative and adjudicative documentation  associated with DISCO determinations of clearance eligibility for industry  security clearance cases. We started by randomly selecting 50 cases from  the population of 1,685 initial clearance applications adjudicated by  DISCO during January and February 2006. Once our sample was selected,  we obtained paper copies of the completely adjudicated case files. We  developed a data collection instrument that incorporated information from  sources such as the federal investigative standards and adjudicative  guidelines, OPM’s Investigator’s Handbook (Draft Version 5), and DOD’s  Personnel Security Research Center’s Quality Rating Form—an analysis  tool to help DOD adjudicators assess the quality of investigative reports  used to make adjudication decisions. Our staff who developed the  instrument then trained other members of our team on how to use the  instrument in order to ensure the accuracy and consistency of data entry.  We refined our instrument utilizing feedback from DOD’s Personnel  Security Research Center staff and our pretest of the instrument on cases  not included in our sample of 50 cases. To ensure the accuracy of our  work, a second team member independently verified information that  another team member had initially coded. As part of each review, we  examined each report of investigation to ensure that all of the investigative  requirements had been met (e.g., neighborhood reference checks) and to  determine if issues that were raised as part of the investigation had been  resolved by OPM investigators. After a thorough review of the  investigative report and associated materials, we reviewed the JPAS  adjudicative report. The JPAS report showed the final adjudicative  decision, including any guidelines that were applied and any mitigating  information. Our assessment of each case was entered into an electronic  database and analyzed to determine the completeness of the files and to  identify areas of deficiency. In addition to obtaining statistical findings, we  identified 8 cases that best illustrated several types of deficiencies  identified by our reviews and statistical analyses. We then met with  investigations and adjudications experts from the Defense Security Service  Academy to discuss several cases. We also discussed our findings for each  of the 8 cases with investigative experts from OPM’s Quality Management  group and adjudication experts from DISCO. By discussing the issues  contained in each case with OPM and DOD experts, we were able to learn  more about the causes of the incomplete documentation and confirm the  accuracy of our observations on 16 percent of our sampled cases. We  performed our work from September 2005 through August 2006 in  accordance with generally accepted government auditing standards.
section_title: Appendix II: Criteria for Determining Clearance Eligibility
paragraphs: In making determinations of eligibility for security clearances, the federal  guidelines require adjudicators to consider (1) guidelines covering 13  specific areas, (2) adverse conditions or conduct that could raise a  security concern and factors that might mitigate (alleviate) the condition  for each guideline, and (3) general factors related to the whole person.  First, the guidelines state that clearance decisions require a common-sense  determination of eligibility for access to classified information based upon  careful consideration of the following 13 areas:  allegiance to the United States; foreign influence, such as having a family member who is a citizen of a  foreign country; foreign preference, such as performing military service for a foreign  country;   personal conduct, such as deliberately concealing or falsifying relevant  facts when completing a security questionnaire; emotional, mental, and personality disorders;    outside activities, such as providing service to or being employed by a    misuse of information technology systems.
Second, for each of these 13 areas, the guidelines specify (1) numerous  significant adverse conditions or conduct that could raise a security  concern that may disqualify an individual from obtaining a security  clearance and (2) mitigating factors that could allay those security  concerns, even when serious, and permit granting a clearance. For  example, the financial consideration guideline states that individuals could  be denied security clearances based on having a history of not meeting  financial obligations. However, this adverse condition could be set aside  (referred to as mitigated) if one or more of the following factors were  present: the financial condition was not recent, resulted from factors  largely beyond the person’s control (e.g., loss of employment), or was  addressed through counseling.
Third, the adjudicator should evaluate the relevance of an individual’s  overall conduct by considering the following general factors:  the nature, extent, and seriousness of the conduct; the circumstances surrounding the conduct, to include knowledgeable  participation; the frequency and recency of the conduct; the individual’s age and maturity at the time of the conduct; the voluntariness of participation; the presence or absence of rehabilitation and other pertinent behavioral  changes; the motivation for the conduct; the potential for pressure, coercion, exploitation, or duress; and  the likelihood of continuation or recurrence.
When the personnel security investigation uncovers no adverse security  conditions, the adjudicator’s task is fairly straightforward because there is  no security condition to mitigate.
section_title: Appendix III: Comments from the Office of Management and Budget
section_title: Appendix IV: Comments from the Department of Defense
section_title: Appendix V: Comments from the Office of Personnel Management
section_title: Appendix VI: Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the contact above, Jack E. Edwards, Assistant Director; Jim  D. Ashley; Jerome A. Brown; Kurt A. Burgeson; Susan C. Ditto; David S.  Epstein; Cindy K. Gilbert; Cynthia L. Grant; Sara G. Hackley; James P.  Klein; Ron La Due Lake; Kenneth E. Patton; and Jennifer L. Young made  key contributions to this report.
section_title: Related GAO Products
paragraphs: DOD Personnel Clearances: Questions and Answers for the Record  Following the Second in a Series of Hearings on Fixing the Security  Clearance Process. GAO-06-693R. Washington, D.C.: June 14, 2006.
DOD Personnel Clearances: New Concerns Slow Processing of Clearances  for Industry Personnel. GAO-06-748T. Washington, D.C.: May 17, 2006.
DOD Personnel Clearances: Funding Challenges and Other Impediments  Slow Clearances for Industry Personnel. GAO-06-747T. Washington, D.C.:  May 17, 2006.
Managing Sensitive Information: DOE and DOD Could Improve Their  Policies and Oversight. GAO-06-531T. Washington, D.C.: March 14, 2006.
GAO’s High-Risk Program. GAO-06-497T. Washington, D.C.: March 15,  2006.
Managing Sensitive Information: Departments of Energy and Defense  Policies and Oversight Could Be Improved. GAO-06-369. Washington,  D.C.: March 7, 2006.
Questions for the Record Related to DOD’s Personnel Security Clearance  Program and the Government Plan for Improving the Clearance Process.  GAO-06-323R. Washington, D.C.: January 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.
Defense Management: Better Review Needed of Program Protection  Issues Associated with Manufacturing Presidential Helicopters. GAO-06- 71SU. Washington, D.C.: November 4, 2005.
Questions for the Record Related to DOD’s Personnel Security Clearance  Program. GAO-05-988R. Washington, D.C.: August 19, 2005.
Industrial Security: DOD Cannot Ensure Its Oversight of Contractors  under Foreign Influence Is Sufficient. GAO-05-681. Washington, D.C.: July  15, 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.
Defense Management: Key Elements Needed to Successfully Transform  DOD Business Operations. GAO-05-629T. Washington, D.C.: April 28,  2005.
Maritime Security: New Structures Have Improved Information  Sharing, but Security Clearance Processing Requires Further Attention.  GAO-05-394. Washington, D.C.: April 15, 2005.
DOD’s High-Risk Areas: Successful Business Transformation Requires  Sound Strategic Planning and Sustained Leadership. GAO-05-520T.  Washington, D.C.: April 13, 2005.
GAO’s 2005 High-Risk Update. GAO-05-350T. Washington, D.C.: February  17, 2005.
High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January  2005.
Intelligence Reform: Human Capital Considerations Critical to 9/11  Commission’s Proposed Reforms. GAO-04-1084T. Washington, D.C.:  September 14, 2004.
DOD Personnel Clearances: Additional Steps Can Be Taken to Reduce  Backlogs and Delays in Determining Security Clearance Eligibility for  Industry Personnel. GAO-04-632. Washington, D.C.: May 26, 2004.
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.
Security Clearances: FBI Has Enhanced Its Process for State and Local  Law Enforcement Officials. GAO-04-596. Washington, D.C.: April 30, 2004.
Industrial Security: DOD Cannot Provide Adequate Assurances That Its  Oversight Ensures the Protection of Classified Information. GAO-04-332.  Washington, D.C.: March 3, 2004.
DOD Personnel Clearances: DOD Needs to Overcome Impediments to  Eliminating Backlog and Determining Its Size. GAO-04-344. Washington,  D.C.: February 9, 2004.
Aviation Security: Federal Air Marshal Service Is Addressing Challenges  of Its Expanded Mission and Workforce, but Additional Actions Needed.  GAO-04-242. Washington, D.C.: November 19, 2003.
Results-Oriented Cultures: Creating a Clear Linkage between Individual  Performance and Organizational Success. GAO-03-488. Washington, D.C.:  March 14, 2003.
Defense Acquisitions: Steps Needed to Ensure Interoperability of  Systems That Process Intelligence Data. GAO-03-329. Washington D.C.:  March 31, 2003.
Managing for Results: Agency Progress in Linking Performance Plans  With Budgets and Financial Statements. GAO-02-236. Washington D.C.:  January 4, 2002.
Central Intelligence Agency: Observations on GAO Access to Information  on CIA Programs and Activities. GAO-01-975T. Washington, D.C.: July 18,  2001.
Determining Performance and Accountability Challenges and High  Risks. GAO-01-159SP. Washington, D.C.: November 2000.
DOD Personnel: More Consistency Needed in Determining Eligibility for  Top Secret Security Clearances. GAO-01-465. Washington, D.C.: April 18,  2001.
DOD Personnel: More Accurate Estimate of Overdue Security Clearance  Reinvestigations Is Needed. GAO/T-NSIAD-00-246. Washington, D.C.:  September 20, 2000.
DOD Personnel: More Actions Needed to Address Backlog of Security  Clearance Reinvestigations. GAO/NSIAD-00-215. Washington, D.C.:  August 24, 2000.
Security Protection: Standardization Issues Regarding Protection of  Executive Branch Officials. GAO/T-GGD/OSI-00-177. Washington, D.C.:  July 27, 2000.
Security Protection: Standardization Issues Regarding Protection of  Executive Branch Officials. GAO/GGD/OSI-00-139. Washington, D.C.: July  11, 2000.
Computer Security: FAA Is Addressing Personnel Weaknesses, But  Further Action Is Required. GAO/AIMD-00-169. Washington, D.C.: May 31,  2000.
DOD Personnel: Weaknesses in Security Investigation Program Are  Being Addressed. GAO/T-NSIAD-00-148. Washington, D.C.: April 6, 2000.
DOD Personnel: Inadequate Personnel Security Investigations Pose  National Security Risks. GAO/T-NSIAD-00-65. Washington, D.C.: February  16, 2000.
DOD Personnel: Inadequate Personnel Security Investigations Pose  National Security Risks. GAO/NSIAD-00-12. Washington, D.C.: October  27, 1999.
Background Investigations: Program Deficiencies May Lead DEA to  Relinquish Its Authority to OPM. GAO/GGD-99-173. Washington, D.C.:  September 7, 1999.
Department of Energy: Key Factors Underlying Security Problems at  DOE Facilities. GAO/T-RCED-99-159. Washington, D.C.: April 20, 1999.
Performance Budgeting: Initial Experiences Under the Results Act in  Linking Plans With Budgets. GAO/AIMD/GGD-99-67. Washington, D.C.:  April 12, 1999.
Military Recruiting: New Initiatives Could Improve Criminal History  Screening. GAO/NSIAD-99-53. Washington, D.C.: February 23, 1999.
Executive Office of the President: Procedures for Acquiring Access to  and Safeguarding Intelligence Information. GAO/NSIAD-98-245.  Washington, D.C.: September 30, 1998.
Inspectors General: Joint Investigation of Personnel Actions Regarding  a Former Defense Employee. GAO/AIMD/OSI-97-81R. Washington, D.C.:  July 10, 1997.
Privatization of OPM’s Investigations Service. GAO/GGD-96-97R.  Washington, D.C.: August 22, 1996.
Cost Analysis: Privatizing OPM Investigations. GAO/GGD-96-121R.  Washington, D.C.: July 5, 1996.
Personnel Security: Pass and Security Clearance Data for the Executive  Office of the President. GAO/NSIAD-96-20. Washington, D.C.: October 19,  1995.
Privatizing OPM Investigations: Implementation Issues. GAO/T-GGD- 95-186. Washington, D.C.: June 15, 1995.
Privatizing OPM Investigations: Perspectives on OPM’s Role in  Background Investigations. GAO/T-GGD-95-185. Washington, D.C.: June  14, 1995.
Security Clearances: Consideration of Sexual Orientation in the  Clearance Process. GAO/NSIAD-95-21. Washington, D.C.: March 24, 1995.
Background Investigations: Impediments to Consolidating  Investigations and Adjudicative Functions. GAO/NSIAD-95-101.  Washington, D.C.: March 24, 1995.
Managing DOE: Further Review Needed of Suspensions of Security  Clearances for Minority Employees. GAO/RCED-95-15. Washington, D.C.:  December 8, 1994.
Personnel Security Investigations. GAO/NSIAD-94-135R. Washington,  D.C.: March 4, 1994.
Classified Information: Costs of Protection Are Integrated With Other  Security Costs. GAO/NSIAD-94-55. Washington, D.C.: October 20, 1993.
Nuclear Security: DOE’s Progress on Reducing Its Security Clearance  Work Load. GAO/RCED-93-183. Washington, D.C.: August 12, 1993.
Personnel Security: Efforts by DOD and DOE to Eliminate Duplicative  Background Investigations. GAO/RCED-93-23. Washington, D.C.: May 10,  1993.
Administrative Due Process: Denials and Revocations of Security  Clearances and Access to Special Programs. GAO/T-NSIAD-93-14.  Washington, D.C.: May 5, 1993.
DOD Special Access Programs: Administrative Due Process Not  Provided When Access Is Denied or Revoked. GAO/NSIAD-93-162.  Washington, D.C.: May 5, 1993.
Security Clearances: Due Process for Denials and Revocations by  Defense, Energy, and State. GAO/NSIAD-92-99. Washington, D.C.: May 6,  1992.
Due Process: Procedures for Unfavorable Suitability and Security  Clearance Actions. GAO/NSIAD-90-97FS. Washington, D.C.: April 23, 1990.
Weaknesses in NRC’s Security Clearance Program. GAO/T-RCED-89-14.  Washington, D.C.: March 15, 1989.
Nuclear Regulation: NRC’s Security Clearance Program Can Be  Strengthened. GAO/RCED-89-41. Washington, D.C.: December 20, 1988.
Nuclear Security: DOE Actions to Improve the Personnel Clearance  Program. GAO/RCED-89-34. Washington, D.C.: November 9, 1988.
Nuclear Security: DOE Needs a More Accurate and Efficient Security  Clearance Program. GAO/RCED-88-28. Washington, D.C.: December 29,  1987.
National Security: DOD Clearance Reduction and Related Issues.  GAO/NSIAD-87-170BR. Washington, D.C.: September 18, 1987.
Oil Reserves: Proposed DOE Legislation for Firearm and Arrest  Authority Has Merit. GAO/RCED-87-178. Washington, D.C.: August 11,  1987.
Embassy Blueprints: Controlling Blueprints and Selecting Contractors  for Construction Abroad. GAO/NSIAD-87-83. Washington, D.C.: April 14,  1987.
Security Clearance Reinvestigations of Employees Has Not Been Timely  at the Department of Energy. GAO/T-RCED-87-14. Washington, D.C.: April  9, 1987.
Improvements Needed in the Government’s Personnel Security Clearance  Program. Washington, D.C.: April 16, 1985.
Need for Central Adjudication Facility for Security Clearances for Navy  Personnel. GAO/GGD-83-66. Washington, D.C.: May 18, 1983.
Effect of National Security Decision Directive 84, Safeguarding  National Security Information. GAO/NSIAD-84-26. Washington, D.C.:  October 18, 1983.
Faster Processing of DOD Personnel Security Clearances Could Avoid  Millions in Losses. GAO/GGD-81-105. Washington, D.C.: September 15,  1981.
Lack of Action on Proposals To Resolve Longstanding Problems in  Investigations of Federal Employees. FPCD-79-92. Washington, D.C.:  September 25, 1979.
Costs of Federal Personnel Security Investigations Could and Should Be  Cut. FPCD-79-79. Washington, D.C.: August 31, 1979.
Proposals to Resolve Longstanding Problems in Investigations of Federal  Employees. FPCD-77-64. Washington, D.C.: December 16, 1977.
Personnel Security Investigations: Inconsistent Standards and  Procedures. B-132376. Washington, D.C.: December 2, 1974.