Personnel Security Clearances: Progress Has Been Made to Improve Timeliness but Continued Oversight Is Needed to Sustain Momentum
Released: 2010-12-01T00:00:00

Letter

Background

Personnel security clearances are required for access to certain national security information, which may be classified at one of three levels: confidential, secret, or top secret. A top secret clearance is generally also required for access to Sensitive Compartmented Information or Special Access Programs. 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 security. Unauthorized disclosure could reasonably be expected to cause (1) “damage,” in the case of confidential information; (2) “serious damage,” in the case of secret information; and (3) “exceptionally grave damage,” in the case of top secret information. To ensure the trustworthiness and reliability of personnel in positions with access to classified information, government agencies rely on a multiphased personnel security clearance process that includes the application submission phase, investigation phase, and adjudication phase.

The application submission phase. A security officer from an agency (1) requests an investigation of an individual requiring a clearance; (2) forwards a personnel security questionnaire (standard form 86) using OPM’s e-QIP system or a paper copy of the standard form 86 to the individual to complete; (3) reviews the completed questionnaire; and (4) sends the questionnaire and supporting documentation, such as fingerprints, to OPM or the investigation service provider.

The investigation phase. Federal investigative standards and OPM’s internal guidance are used to conduct and document the investigation of the applicant. The scope of information gathered in an investigation depends on the level of clearance needed and whether an investigation for an initial clearance or reinvestigation for a clearance renewal is being conducted. For example, the federal standards require that investigators collect information from national agencies, such as the Federal Bureau of Investigation, for all initial and renewal clearances. For an investigation for a confidential or secret clearance, investigators gather much of the information electronically. For an investigation for a top secret clearance, investigators gather additional information through more time-consuming efforts, such as traveling to conduct in-person interviews to corroborate information about an applicant’s employment and education. After the investigation is complete, the resulting investigative report is provided to the agency. According to the Performance Accountability Council’s Strategic Framework, for the purposes of IRTPA timeliness reporting, investigative time is the time in days from the receipt date of the completed personnel security package by the investigative service provider to the date the final investigative file is forwarded to the adjudicative facility if sent electronically.

The adjudication phase. Adjudicators from an agency use the information from the investigative report to determine whether an applicant is eligible for a security clearance. To make clearance eligibility decisions, federal requirements specify that adjudicators consider guidelines in 13 specific areas that elicit information about (1) conduct that could raise security concerns and (2) factors that could allay those security concerns and permit granting a clearance. According to the Performance Accountability Council’s Strategic Framework, for the purposes of IRTPA timeliness reporting, adjudicative time is the time in days from the date the final investigative file is forwarded (or received electronically) to the adjudicative unit to the date of the adjudicative decision.

Separate from, but related to, security clearances, are suitability determinations. Executive branch agencies conduct additional suitability investigations for individuals to ensure that they are suitable for employment in certain positions. For example, the Department of Justice conducts additional suitability checks to ensure applicants for jobs with the Drug Enforcement Agency have not used drugs. In addition, Health and Human Services conducts additional suitability investigations on applicants for jobs working with children. Similarly, the Intelligence Community requires a polygraph evaluation, among other things, to determine suitability for most positions.

In light of long-standing delays and backlogs in processing security clearances, Congress set goals and established requirements for improving the clearance process in the Intelligence Reform and Terrorism Prevention Act of 2004. In 2005, GAO designated DOD’s personnel security clearance program as a high risk area. As can be seen in figure 1, a number of steps have been taken to reform the process, including: Role of the Office of Management and Budget in security clearance process. In June 2005, the President issued an executive order as part of the administration’s efforts to improve the security clearance process and implement the statutory clearance requirements in IRTPA. This order tasked the Director of OMB with a variety of functions in order to ensure that agency processes relating to determining eligibility for access to classified national security information were appropriately uniform, centralized, efficient, effective, timely, and reciprocal. These actions included taking a lead role in preparing a November 2005 plan to improve the timeliness of personnel security clearance processes governmentwide.

Formation of the Joint Reform Team. The Joint Security Process Reform Team, also known as the Joint Security and Suitability Reform Team or Joint Reform Team, formed in June 2007, was established by the Director of National Intelligence and Under Secretary of Defense for Intelligence through a memorandum of agreement to execute joint reform efforts to achieve IRTPA timeliness goals and improve the processes related to granting security clearances and determining suitability for government employment. Agencies included in this governmentwide reform effort are ODNI, DOD, OMB, and OPM. The Joint Reform Team continues to work on the reform effort under the Performance Accountability Council by providing progress reports, recommending research priorities, and overseeing the development and implementation of an information technology strategy, among other things. Since its formation, the Joint Reform Team under the Performance Accountability Council: (1) Submitted an initial reform plan to the President on April 30, 2008. The plan proposed a new process for determining clearance eligibility that departs from the current system in a number of ways, including the use of a more sophisticated electronic application, a more flexible investigation process, and the establishment of ongoing evaluation procedures between formal clearance investigations. The report was updated in December 2008 to include an outline of reform progress and further plans. (2) Issued an Enterprise Information Technology Strategy to support the reformed security and suitability process in March 2009. According to the report, the Joint Reform Team is pursuing an approach that leverages existing systems and capabilities, where applicable, and developing new tools where necessary.

Formation of the Performance Accountability Council. Executive Order 13467 established the leadership structure for security and suitability reform headed by the Suitability and Security Clearance Performance Accountability Council as the entity responsible for aligning security and suitability, holding agencies accountable for implementation, and overseeing progress toward the reformed vision. This executive order directed, among other things, that executive branch policies and procedures be aligned and use consistent standards, to the extent possible, for investigating and adjudicating whether an individual is (1) suitable for government employment, (2) fit to be a contract employee, or (3) eligible for access to classified information. The Performance Accountability Council is accountable to the President to achieve reform goals and also oversees newly designated Security and Suitability Executive Agents. The executive order designated the Director of National Intelligence as the Security Executive Agent, the Director of OPM as the Suitability Executive Agent, and the Deputy Director for Management at OMB as the chair of the council with the authority to designate officials from additional agencies to serve as members. The council currently comprises representatives from 11 executive agencies. In May 2010, the Performance Accountability Council proposed quality measures to address the different phases of the application process including validating need, e- application, investigation, and adjudication. The measures also include the responsible organization, population covered, collection method, and whether it is a current or future measure.

Strategic Framework. The Performance Accountability Council issued a Strategic Framework in February 2010 to articulate the goals of the security and suitability process reform. The Strategic Framework sets forth a mission and strategic goals, performance measures, a communications strategy, roles and responsibilities, and metrics to measure the quality of security clearance investigations and adjudications.

Significant Overall Progress Has Been Made to Improve Timeliness, but Some Executive Agencies Continue to Face Challenges in Meeting Timeliness Objectives

Timeliness Varies Across Agencies

The government has reported that significant overall progress has been made to improve the investigation and adjudication of personnel security clearance applications in a timely manner. This is largely attributable to DOD, whose clearances comprise a vast majority of governmentwide initial clearances. IRTPA required the executive branch to develop a plan under which, to the extent practical, each authorized adjudicative agency would be required to make a determination on at least 90 percent of initial security clearances within an average of 60 days by December 17, 2009. Within this 60-day period, IRTPA also includes periods of 40 days for investigations and 20 days for adjudications. As can be seen in figure 2, according to the Performance Accountability Council’s February 2010 annual report to Congress, during the first quarter of fiscal year 2010, two agencies—the National Geospatial-Intelligence Agency and the National Reconnaissance Office—met the timeliness requirement for investigations, seven agencies—the Departments of Defense, Energy, Health and Human Services, the Defense Intelligence Agency, the National Security Agency, the Federal Bureau of Investigation, and the Department of State—met the timeliness objectives for adjudications, and five agencies—the Department of Defense, Department of Energy, the National Geospatial-Intelligence Agency, the National Reconnaissance Office, and the Department of State—met the 60-day IRTPA timeliness objective. Furthermore, we found that one of the agencies included in our review—the National Geospatial-Intelligence Agency—met all of the IRTPA timeliness objectives for the second and third quarter, while the Defense Intelligence Agency met all of the IRTPA timeliness objectives in the second quarter and DOD, which comprises the vast majority of clearances, and the Federal Bureau of Investigation, met all of the IRTPA timeliness objectives in the third quarter of fiscal year 2010.

We also found that timeliness varied widely among executive branch agencies. During the first three quarters of fiscal year 2010, the average for the fastest 90 percent of cases adjudicated by the 14 agencies included in our review ranged from 22 to 96 days for investigation timeliness, 2 to 59 days for adjudication timeliness, and 30 to 154 days for IRTPA timeliness. Agency officials that we spoke with largely attributed the wide variation between these agencies to variances in the adoption of information technology. According to OPM officials, timeliness varies for the agencies that use OPM as the investigative service provider due, in part, to differences in agency adoption of information technology, such as the e- QIP that speeds up investigation timeliness by providing OPM with more complete and better quality data earlier in the process. With regard to adjudication timeliness, five of the agencies we included in our review have developed electronic delivery, electronic adjudication, or case management and workflow tools to improve timeliness, while others have not.

Agencies Have Made Efforts to Improve Timeliness for Processing Security Clearances

The requirements established by IRTPA have resulted in a governmentwide focus on improving the timeliness of initial security clearances through the Performance Accountability Council. In addition, several of the agency officials with whom we spoke reported that their agencies prioritize timeliness for security clearances. For example, several agency officials noted that the passage of IRTPA was an important factor leading to continued senior level leadership commitment, involvement, and oversight over timeliness reform through the Performance Accountability Council. Moreover, IRTPA’s annual reporting requirements have provided more information about agency timeliness to Congress, allowing for more oversight and increasing transparency and accountability. However, IRTPA does not set timeliness requirements for suitability determinations, Homeland Security Presidential Directive-12 investigations, and security clearance renewals. According to agency officials we spoke to, their agencies often prioritize initial security clearances for processing.

Governmentwide efforts to improve the timeliness of personnel security clearance processing have focused on technology solutions. For example, the Joint Reform Team and the Performance Accountability Council have encouraged agencies to utilize information technology solutions, such as e-QIP, electronic delivery, and electronic adjudication capabilities to enhance automation. E-QIP facilitates more complete collection of a subject’s information upfront in the process and reduces errors, which lowers, on average, the time it takes for investigators to clarify the information provided. Electronic delivery reduces the adjudicative phase by eliminating delays in receiving investigative reports related to mail and courier services, such as the need at certain agencies to irradiate all incoming mail. Electronic adjudication systems use automation to review investigative reports for missing information and adjudicate the cases, under certain conditions, within seconds. Agency officials indicated that as agencies have adopted these capabilities, timeliness improved. In addition, OPM, which performs approximately 94 percent of initial clearance investigations for the federal government, has also taken steps to improve timeliness. For example, according to OPM officials, OPM also made information technology enhancements to improve its processes, such as enabling electronic delivery.

Aside from these governmentwide efforts, some agency officials stated that their agencies have taken steps to improve adjudication timeliness. DOD, for example, developed and implemented an electronic case management system—the Clearance Adjudication Tracking System— within several of its Central Adjudication Facilities. In 2009, the Army began electronically adjudicating secret clearances through the Clearance Adjudication Tracking System, which was a significant factor in improving the Army’s adjudicative average timeliness. For example, according to the Performance Accountability Council’s Strategic Framework, the average of the fastest 90 percent of initial clearance adjudications for the Army fell from 187 days in the second quarter of fiscal year 2009 to 10 days in the first quarter of fiscal year 2010. The Department of Energy also took steps to enhance timeliness. For example, in addition to utilizing electronic delivery and e-QIP, the Department of Energy developed corrective action plans, implemented case prioritization procedures, and created a tiered adjudication structure to clear easier cases quickly while utilizing a complex case review board to address complex cases in a timely manner. In addition, the Department of Energy built timeliness performance into adjudicator evaluations, reduced the number of people involved with deciding cases, and increased manpower to meet workload requirements.

Agencies Continue to Face Several Challenges to Meeting Timeliness Objectives

Despite the actions that have been taken to improve timeliness, agency officials with whom we spoke identified several remaining challenges to meeting IRTPA’s timeliness objectives. These challenges include agency- specific issues, such as resource constraints and manpower limitations. For example: Resource constraints are a limiting factor for several agencies in implementing certain information technology capabilities, such as electronic delivery, case management, and workflow tools. For example, Defense Intelligence Agency officials indicated that they are constrained in implementing a key information technology that provides electronic delivery, case management, and workflow tool capabilities. Furthermore, some agencies, especially those with relatively small clearance caseloads, find it difficult to justify large investments to develop and implement information technology systems.

Personnel limitations, such as personnel shortages or increased workloads, were also identified by several agency officials as an ongoing challenge. Some agency officials stated that their agencies already have or expect to experience personnel shortages. For example, officials from the Department of Homeland Security stated that a lack of resources is the primary issue for not meeting the timeliness objectives, but the Department of Homeland Security headquarters is currently backfilling 10 vacant adjudicator positions, which should help to alleviate the problem. In addition, some agency officials stated that their agency staff is subject to workload increases, such as periods of increased agency hiring, spikes in security clearance renewal cases, or additional duties related to corollary requirements. For example, in 2008, Homeland Security Presidential Directive-12 directed the implementation of a common governmentwide identification standard for federal employees and contractors, under which federal agencies have been required to begin issuing common identification and access badges for all individuals, including contractors, who need access to government facilities or computer networks. These badge requirements, while different from those required for security clearances, expanded the pool of staff needing investigations and adjudicative determinations. These issues are particularly challenging in places where staff already perform clearance processes as a collateral duty.

We found other challenges to meeting timeliness objectives that were the result of systemic issues involving interagency and intergovernmental activities. Agencies are often unable to control certain processes in order to meet timeliness objectives when they are dependent on information or action from other governmental entities. For example: Information-sharing between agencies is an ongoing challenge that can manifest itself in several ways. First, investigative agencies are not in direct control of the timeliness and completeness of Federal Bureau of Investigation, state, and local law enforcement fingerprint and criminal investigation checks. For example, the results of Federal Bureau of Investigation criminal investigation checks often are returned with a classification listed as “No Pertinent,” which indicates that there is no pertinent information relevant to making a clearance eligibility determination. Some agency officials with whom we spoke indicated that this type of response leaves adjudicators with incomplete information due to the potential that the designation is either the result of a subjective judgment from an outside party as to what they believe is relevant information or a placeholder to indicate that more information is potentially available, but pending or not releasable. Second, officials said the lack of digitization of records at certain federal, state, and local agencies can be a challenge to gathering information for timely completion of investigations and adjudicative decisions. When personnel files, for example, are not stored, catalogued, and made searchable through electronic means, agencies are limited by manual checks. Finally, delays and incomplete information may occur in obtaining information from intelligence agencies. For example, some agency officials with whom we spoke stated that since they do not have direct access to clearance-related information and databases for agencies in the Intelligence Community, they rely upon manual requests for information.

Investigation services quality and cost is an ongoing challenge to meeting timeliness objectives, according to agencies officials. For example, officials representing the Departments of Homeland Security, Energy, the Treasury, Justice, and four DOD component agencies that utilize OPM as their investigative service provider cited challenges related to deficient investigative reports as a factor that slows agencies’ abilities to make adjudicative decisions. The quality and completeness of investigative reports directly affects adjudicator workloads, including whether additional steps are required before adjudications can be made, as well as agency costs. For example, some agency officials we spoke with noted that OPM investigative reports do not include complete copies of associated police reports and criminal record checks. According to ODNI and OPM officials, OPM investigators provide a summary of police and criminal reports and assert that there is no policy requiring inclusion of copies of the original records. However, ODNI officials also stated that adjudicators may want or need entire records as critical elements may be left out. For example, according to Defense Office of Hearings and Appeals officials, in one case, an investigator’s summary of a police report incorrectly identified the subject as a thief when the subject was actually the victim. If the Defense Office of Hearings and Appeals had access to actual police documents, officials believe the adjudication process would be more efficient. We noted in our prior work that documentation was incomplete for most OPM-provided investigative reports based on independent review of about 3,500 investigative reports. We also noted in our previous work that incomplete investigative documentation may lead to increases in the time it takes to complete the clearance process and the overall costs of the process. Several agency officials stated that in order to avoid further costs or delays they often choose to perform additional steps internally to obtain missing information, clarify or explain issues identified in investigative reports, or gather evidence for issue resolution or mitigation.

Finally, a significant challenge to meeting timeliness objectives specific to Intelligence Community agencies involve addressing the requirements that are unique to these agencies. For example, since most positions in Intelligence Community agencies require top secret clearances with Sensitive Compartmented Information access, intelligence agencies rely almost exclusively on Single Scope Background Investigations that are required for these types of clearances. These investigations have higher requirements for the types and numbers of sources of information required compared to investigations for secret or confidential clearances. According to agency officials, these higher requirements take longer, on average, to investigate and adjudicate. In addition, timeliness for intelligence agencies is often complicated by the unique issues presented by extensive suitability determination processes and precise conditions of employment that may include medical exams, psychological evaluations, drug testing, and polygraph exams. Polygraph exams, for example, may generate additional leads that require further investigative work. Moreover, agency officials also stated that scheduling a polygraph with an individual, especially if they live far from agency offices, may add months to investigation timelines.

Performance Accountability Council Has Not Reported on Impediments to Meeting Timeliness Objectives or Plans to Address Impediments

While the Performance Accountability Council, responsible for driving implementation of the reform effort and ensuring accountability, has taken steps to assist in implementation of reform efforts, it has not reported on the impediments to meeting timeliness objectives or plans to address impediments. IRTPA’s security clearance reform provision requires annual reports to the appropriate congressional committees—through 2011—on the progress made during the preceding year toward meeting its requirements, including timeliness data and a discussion of any impediments to the smooth and timely functioning of its requirements. However, in its most recent report to Congress, the Performance Accountability Council did not provide information on the impediments agencies face in meeting timeliness objectives or plans to address impediments. While the Office of the Director of National Intelligence, in its capacity as Security Executive Agent, has performed a limited number of oversight audits, according to officials at four agencies we met with, the Performance Accountability Council has not met with them to identify the impediments to meeting the timeliness objectives. The Performance Accountability Council has focused its efforts on DOD in part due to DOD’s security clearance program’s designation as one of GAO’s high-risk areas, as well as the fact that DOD clearances comprise the overwhelming majority of initial clearance cases that are processed annually. We found that due to the relative size of DOD’s clearance program, DOD’s progress towards meeting IRTPA’s timeliness objectives is a significant factor in reducing the average time required for initial security clearance processing for the government as a whole. Furthermore, Performance Accountability Council officials stated that they will begin conducting one-on-one meetings with individual agencies in September 2010 to enhance communication, assist in implementation planning, and provide a feedback mechanism for agency stakeholders to communicate information and needs to the Joint Reform Team.

The Performance Accountability Council is in a position to identify certain trends and commonalities, such as those challenges related to resource constraints, manpower limitations, information-sharing, investigation services quality and cost, and Intelligence Community specific issues. However, absent complete reporting on the impediments on meeting timeliness objectives, Congress may not have visibility over agency compliance and decision makers may not have a complete picture of the progress made or the impediments to meeting timeliness objectives. This potential lack of agency transparency and accountability may impact continued efforts to improve timeliness and prevent scrutiny over agencies that are not meeting timeliness objectives.

Executive Agencies Often Grant Reciprocity, Although Challenges Exist to Measuring and Tracking Reciprocity

Executive Agency Officials Reported That They Routinely Honor Another Agency’s Security Clearance, but Additional Steps May Be Taken before Granting Reciprocity

Officials representing executive branch agencies, including those within the Intelligence Community, stated that they routinely grant reciprocity (i.e., accept a background investigation or clearance determination completed by another authorized investigative or adjudicative agency). IRTPA generally requires that all security clearance investigations and determinations be accepted by all agencies, with limited exceptions when necessary for national security purposes. We have reported in the past that, according to the government’s plan for addressing problems in the personnel security clearance process, security clearances are not fully accepted governmentwide. A recent congressional committee report also suggests that even among the elements of the Intelligence Community, there are impediments and sometimes lengthy delays in granting clearances to employees detailed from one agency to another. However, in October 2008, the ODNI issued guidance on the reciprocity of personnel security clearances. The guidance requires, except in limited circumstances, that all Intelligence Community elements “accept all in- scope security clearance or access determinations.” Further, OMB guidance requires agencies to honor a clearance when: (1) the prior clearance was not granted on an interim or temporary basis, (2) the prior clearance investigation is current and in-scope, (3) there is no new derogatory information, and (4) there are no conditions, deviations, waivers, or unsatisfied additional requirements (such as polygraphs) if the individual is being considered for access to highly sensitive programs. Moreover, officials representing two agencies in our review noted that it is in their best interest to accept a prior clearance because reciprocity saves time, money, or manpower.

Although officials agreed that they routinely honor another agency’s security clearance, we found that some agencies find it necessary to take additional steps to address limitations with available information. Officials representing 18 of the 21 organizations we met with to discuss reciprocity reported that they must address limitations, such as insufficient information in the databases or variances in the scope of investigations, before granting reciprocity. For example: Insufficient information. Although there is no single, integrated database, security clearance information is shared between OPM, DOD, and, to some extent, Intelligence Community databases. OPM has taken steps to ensure certain clearance data necessary for reciprocity is available to adjudicators. For example, in April 2010, OPM held an interagency meeting to determine new data fields to include in their shared database to more fully support reciprocity. However, we found that the shared information available to adjudicators contains summary-level detail that may not be complete. As a result, agencies may take steps to obtain additional information, which creates challenges to immediately granting reciprocity. For example, to accept a clearance granted by an intelligence agency, a non-intelligence agency must access information from the intelligence agencies’ Scattered Castles database. However, according to officials representing the Department of the Treasury, the Department of Justice, and the Joint Chiefs of Staff, the Scattered Castles database does not always provide enough detail to immediately grant reciprocity. According to these officials, the Scattered Castles summary screen is not detailed enough or does not include key information, such as the steps taken to mitigate negative issues. As a result, additional information, such as copies of the original background investigation, must be sought directly from intelligence agencies to verify and provide supporting detail to the information available in Scattered Castles. Similarly, to accept a clearance granted by a non-intelligence agency, an intelligence agency must access information from non-intelligence agency databases. Officials representing Intelligence Community agencies with whom we spoke noted, for example, that they must contact DOD to determine if an actual clearance was granted and verify the current status of the applicant because such detail is not available in DOD’s Joint Personnel Adjudication System. Similarly, officials representing the Department of Justice told us that while OPM’s Central Verification System shows the existence of conditions, deviations, and waivers, Department of Justice officials follow up as appropriate with the agency that granted the clearance.

Variances in the scope of investigations. We found that the scope of background investigations varies by level of clearance, which may lead to duplicative work. For example, a person with a secret-level clearance may have had one of several types of background investigations and the scope of the background investigation may vary depending on the type of clearance sought. Further, officials from two agencies we spoke with told us that they typically require a certain type of background investigation and when a subject’s clearance is based on a different type of investigation, they may take additional steps to fill in the missing gaps to ensure the scope is consistent with their expectations. Officials representing other agencies included in our review told us that when the subject’s existing background investigation is different from the required investigation type, the agency will request a new background investigation. For example, officials at one agency stated that positions of public trust sometimes have higher suitability information requirements than information available from confidential/secret background investigations. Similarly, officials at another agency stated that because there are two types of investigations for secret/confidential clearances based on whether the person is military or contractor or government civilian, the agency may not be able to accept an investigation if it is the wrong one for that particular position. When an entirely new investigation is performed, we found that the current system may lead to duplicative work, limiting reciprocity. In a 2008 report to the President, the Joint Reform Team, under the Performance Accountability Council, proposed revised investigative standards to, among other things, reduce the types of initial investigations from 15 to 3. While originally planned for release in December 2010, the Performance Accountability Council extended plans to issue a new version of the revised Federal Investigative Standards to calendar year 2011.

In addition to addressing limitations with available information, agency officials identified broader challenges to granting reciprocity. Officials representing 14 of the 21 agencies included in our review of reciprocity reported that challenges, such as the need to conduct suitability determinations or determine whether a prior clearance investigation and adjudication meets their quality expectations, must be addressed before granting reciprocity. For example: Conducting suitability determinations. All federal agencies may be required to conduct basic suitability determinations to ensure the applicant’s character or conduct is appropriate for the position in question, but some agencies take additional actions to determine suitability before they reciprocate a security clearance. For example, the Department of Justice must take steps to ensure that applicants for jobs with the Drug Enforcement Administration have not used drugs, according to agency officials. Similarly, the Intelligence Community requires a polygraph evaluation, among other things, to determine suitability for most positions, according to intelligence officials. We also found that agencies have varying standards for determining suitability of applicants before reciprocating a security clearance. For example, Department of Health and Human Services officials said they will not accept a prior security clearance until it makes a favorable determination of suitability.

Similarly, the Department of Justice will only accept another agency’s clearance and hire the applicant on a probationary period pending a favorable suitability determination. As a result of the variances in determining suitability, OPM, as the Suitability Executive Agent for all executive agencies, and the Joint Reform Team have issued guidance in line with Executive Order 13488, which mandates, to the extent practicable and with certain exceptions, reciprocal recognition of prior favorable suitability determinations. For example, OPM issued a memorandum for the Heads of Executive Departments and Agencies that explains how to implement the Executive Order.

Determining whether a prior clearance investigation and adjudication meets standards. Most agency officials we spoke with stated that since there is no governmentwide standardized training and certification process for investigators and adjudicators, a subject’s prior clearance investigation and adjudication may not meet the standards of the inquiring agency. Although OPM has developed some training, security clearance investigators and adjudicators are not required to complete a certain type or number of classes. As a result, the extent to which investigators and adjudicators receive training varies by agency. For example, according to ODNI officials, all DOD adjudicators working at DOD Central Adjudication Facilities must take a basic 2-week adjudicator course and subsequently the 1-week advanced course after some time on the job. However, according to officials we spoke with, the Air Force has an additional requirement for adjudicators to attend a 3-week training course while the Defense Industrial Security Clearance Office relies on on- the-job training. Other agencies have different requirements. For example, the Department of Energy relies on a mandatory annual security refresher. Consequently, as we have previously reported, agencies are reluctant to be accountable for investigations and/or adjudications conducted by other agencies or organizations. To achieve fuller reciprocity, clearance- granting agencies seek to have confidence in the quality of prior investigations and adjudications. The annual reports to Congress indicate that the Performance Accountability Council is taking steps to make investigations and adjudications more consistent across the government by standardizing the training of investigators and adjudicators. For example, the reports describe the development of core courses, as well as a formalized certification for investigators and adjudicators. According to senior leaders of the reform effort, these steps will facilitate reciprocal acceptance of clearance decisions governmentwide.

In the Absence of Consistent Metrics and Reporting Requirements, the Extent to Which Reciprocity Is Granted Is Unknown

Although agency officials have stated that reciprocity is regularly granted, agencies do not have complete records on the extent to which previously granted security clearance investigations and adjudications are honored governmentwide. While the Performance Accountability Council has identified reciprocity as a governmentwide strategic goal, we found that agencies do not consistently and comprehensively track when reciprocity is granted, and lack a standard metric for tracking reciprocity. For example, Department of Justice and Department of Energy officials said they track both when reciprocity is granted and reasons for denying a previously granted security clearance, while Navy and Department of the Treasury officials said they only document when reciprocity is granted and not when reciprocity is denied. The Navy checks a box in its electronic database, and the Department of Energy and the Department of the Treasury manually track when reciprocity is honored. In contrast, the Army and Air Force do not track reciprocity at all, according to agency officials. Moreover, it is unclear the extent to which agencies that do track reciprocity are reporting the data to oversight agencies, such as ODNI, or sharing information on reciprocity with each other.

OPM and the Performance Accountability Council have developed quality metrics for reciprocity, but the metrics do not measure the extent to which reciprocity is being granted. We previously reported that developing metrics for assessing and regularly monitoring all aspects of the clearance process could add value in current and future reform efforts as well as supply better information for greater congressional oversight. While the existing metrics are a positive step, more is needed to comprehensively capture the extent to which reciprocity is being granted. For example, OPM created a metric in early 2009 to track reciprocity, but this metric measures limited information. OPM’s metric measures the number of investigations requested from OPM that are rejected based on the existence of a previous investigation and does not track the number of cases in which reciprocity was or was not successfully honored. The Performance Accountability Council developed quality metrics, including metrics to track reciprocity, in response to a March 2010 congressional inquiry. For example, the Performance Accountability Council proposes as a metric the average percentage of cases for which prior database checks are conducted as reported by executive branch agencies. However, this metric does not account for agencies that checked other databases and relies on agency self-reporting rather than a systematic method of data collection. Although the metric helps to create an overall picture of reciprocity, it does not track which cases were and were not reciprocated. Similarly, the other metrics included in the Performance Accountability Council’s proposal, such as the number of duplicate requests for investigations, percentage of applications submitted electronically, number of electronic applications submitted by applicant but rejected by OPM as unacceptable due to missing information or forms, and percentage of fingerprint submissions determined to be “unclassifiable” by the Federal Bureau of Investigation, provide useful information, but do not track the extent to which reciprocity is or is not ultimately honored.

Although There Are No Plans to Develop a Single, Integrated Database, Steps Have Been Taken to Upgrade Existing Systems and Increase Information Sharing

The Executive Branch Has Opted to Leverage Existing Systems in Lieu of a Single, Integrated Database

Tasked with establishing a single, integrated database, the executive branch has opted to focus on leveraging existing systems rather than establish a new database. IRTPA required that not later than 12 months after the date of enactment of the act, the Director of the Office of Personnel Management and the Director of the Office of Management and Budget establish and commence operating and maintaining a single, integrated database of security clearance information. This database was to house information regarding the granting, denial, or revocation of security clearances or access pertaining to military, civilian, and contractor personnel, from all authorized investigative and adjudicative agencies. Information from this database would be used to validate whether a person has or had a clearance, potentially including such information as the type of investigation that was conducted and the date of the investigation, thereby assisting responsible officials in determining whether a new investigation is required. However, the Performance Accountability Council is not pursuing a single, integrated database according to our analysis of a series of recent reports that the Joint Reform Team, under the Performance Accountability Council, issued between 2008 and 2010. For example, according to the Enterprise Information Technology Strategy, the Performance Accountability Council has opted to pursue an approach that leverages existing systems and involves the development of new tools when necessary. According to the Strategic Framework, which was included with the most recent annual report to Congress, the reform efforts are focused on leveraging OPM’s existing system—the Central Verification System—to enable access to records on investigations and adjudications. Agency officials from both OPM and ODNI confirmed that there are no plans to create a new single, integrated database. Instead, the focus will be on using a single search capability of existing databases as the means by which they intend to address the IRTPA requirement. According to an OPM official with whom we spoke, a single database would not provide any additional functionality over the single-search capability that they are pursuing.

OPM, DOD, and ODNI officials with whom we spoke explained that establishing, operating, and maintaining a single, integrated database is not a viable option due to concerns related to privacy, security, and data ownership. First, DOD and OPM mentioned privacy concerns, which involve the unintentional disclosure of personal identifying information, such as name and Social Security number. Second, merging the different systems into one database raises security concerns. For example, according to an ODNI official, since the Intelligence Community’s database is classified and separate from the databases used by non- intelligence agencies, even an aggregation of unclassified information from its database could lead to unintentional disclosure of personal identifying information that could compromise security. Moreover, breaches in the system could also compromise security. For example, some officials mentioned an enhanced threat from hackers if there were consolidation of multiple information technology systems. Finally, according to DOD officials, there are issues related to data ownership and the copying and transferring of information between systems that are owned by different agencies. For example, according to OPM officials, OPM can not provide information from investigations it did not conduct to another agency. When investigations are conducted by agencies with delegated authority, the reports are owned and maintained by the investigating agency. Requests for these investigative records must be referred to the owning agency.

Information from Two Primary Databases Can Be Accessed from a Single Entry Point

Although there are no plans to create a new governmentwide database, non-intelligence agencies in our review are sharing information about personnel who hold or are seeking security clearances through two main databases that can be accessed through a single entry point. Two primary databases are used by non-intelligence agencies to store investigative and adjudicative information and according to the Performance Accountability Council, they account for decisions on about 90 percent of all security clearance holders in the federal government. Data are stored in either OPM’s Central Verification System or DOD’s Joint Personnel Adjudication System. The Central Verification System includes security clearance data for all non-Intelligence Community, non-DOD executive branch agencies. The Joint Personnel Adjudication System is a repository for security clearance information on both DOD civilian and military personnel, as well as determinations of contractor clearance eligibility and access for the National Industrial Security Program. Data from the two databases can be searched and obtained from a single entry point in the Central Verification System.

The Central Verification System was upgraded in spring 2010 and now provides access to more information than was previously accessible. Specifically, the upgraded system provides users with a summary of information on: Characteristics of clearances reported to the system. This summary includes information on active, inactive, and denied clearances, as well as information on whether there is a condition, deviation, or waiver.

Characteristics of investigations reported to the system. This summary includes information on pending, closed, and discontinued investigations, as well as requests that were deemed unacceptable due to inadequate or inaccurate information.

Suitability and fitness. This summary provides information on adjudication decisions for suitability for federal employees and fitness for excepted service and contract employee determinations.

Homeland Security Presidential Directive-12 Personal Identification Verification Credentials. This summary includes information on the status of credentials issued to the subject indicating whether the credentials are active, suspended, revoked, administratively withdrawn, or other.

Polygraph data. This summary includes information on the type of polygraph conducted, including Counter-Intelligence or Expanded Scope, but does not include results from examinations.

Intelligence Community Agencies Share Information through a Separate Database and Are Exploring Alternatives to Expand Information Sharing with Non- intelligence Agencies

According to ODNI officials and Intelligence Community Directive 704, the Intelligence Community agencies share information with one another through a separate classified database known as Scattered Castles. Scattered Castles is a repository for records from all intelligence agencies by which each agency uploads relevant information from individual agency databases. All personnel who have access to Sensitive Compartmented Information are listed in Scattered Castles. This system is not linked to OPM’s Central Verification System due to concerns about protecting classified information. According to ODNI officials, the system has not been linked to non-intelligence databases due to the need to protect information on covert personnel. However, officials representing Intelligence Community agencies stated that they do enter some information from the Joint Personnel Adjudication System into Scattered Castles.

Although the Intelligence Community maintains a separate database, we found that most of the non-intelligence agencies included in our review had some access to Scattered Castles. For example, five non-intelligence, non-DOD agencies included in our review had some access through a Sensitive Compartmented Information Facility located in their agency. All of the military departments, as well as the Joint Chiefs of Staff, also had some access. Moreover, according to agency officials, DOD adjudicators with the appropriate clearance and need to know will have access to a Sensitive Compartmented Information Facility with access to Scattered Castles when DOD collocates all of its clearance adjudication facilities at Fort Meade in Maryland as part of the DOD base realignment and closure process in 2011.

According to Performance Accountability Council officials, the Performance Accountability Council is participating in an effort to explore ways to enhance information sharing between the Intelligence Community agencies and the non-intelligence agencies. A working group has been established to study alternatives to support a single access point from which to search clearance information and plans to complete its review in December 2010. According to an ODNI official, alternatives currently being considered include a help desk staffed with employees from the Intelligence Community who would have access to the Joint Personnel Adjudication System, Central Verification System, and Scattered Castles and could, upon request, provide the results of Scattered Castles searches to non-Intelligence Community agencies.

Conclusions

Continued personnel security clearance reform relies on strong, committed executive leadership to sustain the momentum created by the current reform effort. This type of leadership commitment, in turn, helps provide oversight and accountability for the improvement processes. Key to these efforts has been the Performance Accountability Council, which has provided direction for clearance reform across the federal government. As a result of the Performance Accountability Council’s actions, federal agencies have made progress in moving closer to the objectives and requirements outlined in IRTPA. Under the Performance Accountability Council’s leadership, timeliness data—particularly at DOD—have improved, steps have been taken to improve information sharing, and there has been focus on honoring reciprocity of existing clearances. However, while agencies are moving closer to meeting the objectives and requirements of IRTPA, continued oversight and accountability for personnel security clearance reform is still needed. Specifically, executive branch agencies that are currently not meeting timeliness objectives may need help in identifying challenges and developing plans with appropriate timelines to overcome these obstacles. The recent activities undertaken by the Performance Accountability Council to assist the agencies in developing plans to implement the reformed approach is a step in the right direction. Continued reporting required by the Intelligence Authorization Act for Fiscal Year 2010 will also help ensure that momentum gained through the reform efforts will continue. However, without developing more comprehensive metrics to track reciprocity, executive branch agencies will not have a complete picture of the degree to which reciprocity is honored.

Recommendations for Executive Action

To improve the overall personnel security reform efforts across the federal government, we recommend that the Deputy Director of Management, Office of Management and Budget, in the capacity as Chair of the Performance Accountability Council, take the following actions: Collaborate with the agencies that are not meeting timeliness objectives to take the following five actions: Identify challenges to timeliness; Develop mitigation strategies to enable each agency to comply with the IRTPA timeliness objectives; Set timelines for accomplishing the required actions; Monitor agency progress; and Report on these plans and progress in the annual reports to Congress.

Develop comprehensive metrics to track reciprocity and then report the findings from the expanded tracking to Congress.

Agency Comments and Our Evaluation

We provided a draft of our report to OMB, ODNI, and OPM. In response to this draft, we received oral comments from OMB and written comments from ODNI and OPM. All three agencies concurred with all of our recommendations. OMB, ODNI, DOD (through ODNI), and OPM also provided us with technical comments, which we incorporated in this report, as appropriate. ODNI and OPM’s written comments are reprinted in their entirety in appendixes II and III, respectively.

In oral comments, OMB generally concurred with both of our recommendations directed to OMB’s Deputy Director of Management in the capacity as Chair of the Performance Accountability Council. OMB noted the report’s thoroughness and that it highlighted the significant progress that has been made to improve the timeliness of security clearance determinations. In response to our recommendations, OMB described some of the steps that the Performance Accountability Council was taking to address the recommendations. Regarding our first recommendation, OMB noted that the Performance Accountability Council was committed to the timeliness and reciprocity goals of IRTPA and that it was working with agencies currently not meeting the IRTPA timeliness goals by taking steps to assist these agencies. Regarding our second recommendation to develop additional performance measures to track reciprocity, OMB stated that the Performance Accountability Council is working to develop these additional metrics.

In written comments, ODNI and OPM both noted the significant overall progress that has been made in the reform efforts. Specifically, ODNI noted that DOD, with the majority of clearances, achieved timeliness goals for adjudications for fiscal year 2010. As we noted in our report, significant overall progress has been made, largely attributable to DOD because the department represents a vast majority of the initial clearances.

In agreeing with and providing comments related to our recommendations, ODNI described a number of ongoing and future actions related to our recommendations. For example, ODNI stated that it is working through the Joint Reform Team to assist executive agencies that are not meeting IRTPA objectives to develop mitigation strategies and will report these strategies to Congress in its February 2011 IRTPA Annual Report. Similarly, ODNI stated that it will continue to work with the Performance Accountability Council’s Performance Management and Measures subcommittee to develop additional measures for reciprocity, timeliness, and quality, which will also be included in its annual report to Congress. We are encouraged to see a continued commitment by executive leaders of the security clearance reform effort and if implemented in accordance with our recommendations, the ODNI’s actions appear to be a positive step in helping sustain the momentum of security clearance reform.

In addition to agreeing with our recommendations, OPM provided four specific comments: First, OPM provided comments on the timeliness data provided by the Performance Accountability Council that we used to frame agency compliance with IRTPA timeliness objectives. Specifically, OPM stated in its written comments that some of the Performance Accountability Council’s timeliness data for the second and third quarters of fiscal year 2010 varies with the data that OPM collects and reports to the Performance Accountability Council. We acknowledge that in some instances there are discrepancies between the timeliness data provided by OPM and the timeliness data that the Performance Accountability Council provided to us. In some cases, OPM asserts that timeliness data for investigations is marginally better than reported by the Performance Accountability Council and in other instances, is marginally worse. However, none of the discrepancies reported by OPM affects our findings as it relates to agency compliance with IRTPA timeliness objectives for the period reported. Agencies we note in figure 2 continue to either meet or not meet the IRTPA timeliness goals. As we note in our methodology, for the purposes of this report, we ultimately selected and relied on data provided by the Performance Accountability Council’s Subcommittee on Performance Management and Measures. The Performance Accountability Council is responsible for collecting and reporting agency timeliness data to Congress and providing oversight to agencies regarding the timeliness of personnel security clearance processes. The data were provided by the Performance Accountability Council in August 2010. We conducted a series of data reliability interviews with knowledgeable officials with the Performance Accountability Council’s subcommittee and concluded that the data provided were sufficiently reliable for our purposes.

Second, OPM also provided comments related to a section of our report on investigation services quality and cost. Specifically, OPM noted in its comments that they felt some policies are ambiguous and that there are customer misperceptions of the sufficiency of OPM investigations.

Further, OPM noted that there is no policy requiring police and criminal records to be included in its investigative reports. The ODNI provided a similar technical comment and we made changes, as appropriate, to reflect this point. However, related to OPM’s comment on agency misperception of the sufficiency of OPM investigations, we spoke with, and note in our report, several agencies stated challenges related to deficient investigative reports provided by OPM. According to these agencies—including DOD, which constitutes the vast majority of personnel security clearances in the federal government—the deficiencies in investigative reports slows their agencies ability to make adjudicative decisions. In fact, as we note in this report and based on our prior work, documentation was incomplete for most OPM-provided investigative reports based on independent review of about 3,500 investigative reports provided to DOD.

Third, OPM suggested modifications to our discussion of quality metrics on reciprocity. In its comments, OPM noted that some of the metrics may have been developed prior to the Performance Accountability Council’s response to a March 2010 congressional inquiry. We disagree with OPM’s characterization of the accuracy of this section and its suggested modification for two reasons: 1) the Performance Accountability Council submitted proposed metrics to congress in May 2010 in response to the congressional inquiry we already note. Our evidence is derived from this letter to congress for which the Performance Accountability Council— including OPM—and GAO are signatories; and 2) OMB, in its capacity as chair of the Performance Accountability Council, stated in its technical comments that referring to the proposed metrics as originating from the Performance Accountability Council was appropriate.

Finally, OPM noted in its comments pertaining to data ownership, that OPM can not provide information from investigations it did not conduct to another agency it did not own. Instead, OPM noted that requests for these investigative records must be referred to the owning agency. As a result, we incorporated changes based on this comment as appropriate.

As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 12 days from the report date. We will then send copies of this report to the Senate Appropriations Committee, Senate Committee on Homeland Security and Governmental Affairs, Senate Select Committee on Intelligence, Senate Armed Services Committee, House Appropriations Committee, House Oversight and Government Reform Committee, and House Armed Services Committee and to members of the Performance Accountability Council, including the Director of the Office of Management and Budget, Office of the Director of National Intelligence, Secretary of the Department of Defense, and the Director of the Office of Personnel Management. In addition, the report will be available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-3604 or farrellb@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix IV.

Appendix I: Scope and Methodology

In conducting our review of the ongoing efforts to reform the personnel security clearance process, the scope of work included the Office of Personnel Management (OPM), the Department of Defense (DOD), and the Office of the Director of National Intelligence (ODNI) as members of the Performance Accountability Council. Our review included select members of the Intelligence Community, including the Under Secretary of Defense for Intelligence, the Central Intelligence Agency, Defense Intelligence Agency, Federal Bureau of Investigation, National Geospatial-Intelligence Agency, National Reconnaissance Office, National Security Agency, and the Department of State. Our review also included six additional executive branch agencies, including the Departments of Energy, Health and Human Services, Homeland Security, Justice, the Treasury, and Veterans Affairs. These agencies were selected based on the volume of initial personnel security clearances they process per year for civilians, military, and industrial personnel, and their use of OPM to conduct background investigations.

Methodology

To assess the overall personnel security clearance reform efforts, as well as each of our objectives, we obtained relevant documentation and interviewed key federal officials from the following organizations: Office of Personnel Management; The Department of Defense; The Office of the Under Secretary of Defense for Intelligence, Department of the Army, Central Clearance Facility, Department of the Navy Central Adjudication Facility, Department of the Air Force Central Adjudication Facility, Defense Industrial Security Clearance Office Central Adjudication Facility, Defense Office of Hearings and Appeals, Defense Personnel Security Research Center, Joint Chiefs of Staff, and Washington Headquarters Services.

Office of the Director of National Intelligence; Department of Health and Human Services; Department of Homeland Security; Department of the Treasury; and Department of Veterans Affairs.

We conducted a roundtable discussion with members of the Intelligence Community, including officials from the Office of the Director of National Intelligence, the Under Secretary of Defense for Intelligence, the Central Intelligence Agency, Defense Intelligence Agency, Federal Bureau of Investigation, National Geospatial-Intelligence Agency, National Reconnaissance Office, National Security Agency, and the Department of State to discuss broader challenges the Intelligence Community faces regarding timeliness, information sharing, and reciprocity.

To assess the extent to which executive branch agencies investigate and adjudicate initial personnel security clearance applications in a timely manner, we analyzed the timeliness objectives specified in the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) and reviewed the self-reported timeliness data contained in the Performance Accountability Council’s Security and Suitability Process Reform Strategic Framework provided by the Performance Accountability Council Subcommittee on Performance Management and Measures for the first three quarters of fiscal year 2010. The data provided by the Performance Accountability Council was provided in August 2010. Further, we obtained and reviewed timeliness data provided by OPM for agencies that utilize OPM as the investigative service provider for the first three quarters of fiscal year 2010. While IRTPA sets timeliness objectives for 90 percent of cases, the Performance Accountability Council excludes certain cases from its analysis before calculating and reporting on agency timeliness. For example, OPM officials stated that cases that are returned to OPM for additional work, such as work to address missing scope items, are excluded from timeliness data. Due to the additional investigative work involved with these cases and the additional time required for agencies to negotiate the terms of the requests, these cases take longer to complete. Furthermore, the Performance Accountability Council excludes certain cases involving industrial personnel. DOD’s Defense Industrial Security Clearance Office adjudicates clearances for industrial personnel. When the Defense Industrial Security Clearance Office cannot mitigate issues and has decided that a denial or revocation is warranted, they submit the cases to the Defense Office of Hearings and Appeals. Timeliness information on cases pending with Defense Office of Hearings and Appeals is excluded from DOD’s timeliness data. Moreover, by not including end-to-end timeliness information on cases that require additional work in the query for calculating the fastest 90 percent of cases, the Performance Accountability Council is excluding many of the cases that took the longest to complete and, therefore, the average for agency timeliness may be reduced. We assessed the reliability of the data by reviewing the existing data and interviewing agency officials knowledgeable about how the data was collected, stored, and reported, as well as the quality assurance steps that were taken to ensure completeness and accuracy. We determined these data were sufficiently reliable for purposes of our audit. Additionally, we supplemented this data reliability analysis with information obtained through our interviews with executive branch agencies about their timeliness performance in fiscal year 2010 to date. These agencies were selected based on the volume of security clearances processed annually, among other things.

To assess the extent to which executive branch agencies accept previously granted security clearances and the challenges, if any, that exist related to reciprocity, we reviewed the requirements specified in IRTPA and analyzed Executive Orders, OMB memorandums, ODNI policy guidance and directives, congressional reports, and individual agency guidance related to reciprocity. We also analyzed existing and planned metrics developed by the Performance Accountability Council to track the extent to which reciprocity is honored. We met with security officials, managers, and adjudicators from DOD, the Intelligence Community, and a non- probability sample of additional executive branch agencies. We supplemented this analysis with information obtained from a roundtable discussion that we conducted with representatives of Intelligence Community agencies to examine the challenges these agencies face as it relates to granting reciprocity. Because the scope of this engagement is limited to security clearances, we did not analyze the extent to which agencies reciprocally accept prior suitability investigations and adjudications. For the purposes of our report reciprocity is an agency’s acceptance of a background investigation or clearance determination completed by another authorized investigative or adjudicative agency. We excluded from the scope of our work issues related to access to facilities, detailed employees, or classified information.

To assess the extent to which executive branch agencies share personnel clearance information in a single, integrated database, we reviewed and analyzed the Joint Reform Team’s Enterprise Information Technology Strategy, the Performance Accountability Council’s 2010 Strategic Framework, and the two most recent Joint Reform Team Security and Suitability Process Reform reports.

We interviewed knowledgeable officials within OPM, ODNI, and DOD to determine what, if any, limitations, barriers, or challenges existed in creating a single, integrated database. In addition, we received demonstrations of both OPM and DOD’s databases and interviewed officials to determine how they shared information about personnel who hold or are seeking security clearances in the absence of a single, integrated database.

We conducted this performance audit from October 2009 through November 2010 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our objectives.

Appendix II: Comments from the Office of the Director of National Intelligence

Appendix III: Comments from the Office of Personnel Management

Appendix IV: GAO Contact and Staff Acknowledgments

Acknowledgments

In addition to the contact named above, Liz McNally (Assistant Director); David Moser (Assistant Director); James Ashley; Joseph M. Capuano; Sara Cradic; Cindy Gilbert; Linda Keefer; James Krustapentus; Greg Marchand; Richard Powelson; Jillena Roberts; and Amie Steele made key contributions to this report.

Related GAO Products

DOD Personnel Security Clearance Reform: Preliminary Observations on Timeliness and Quality. GAO-11-185T. Washington, D.C.: November 16, 2010.

Privacy: OPM Should Better Monitor Implementation of Privacy-Related Policies and Procedures for Background Investigations. GAO-10-849. Washington, D.C.: September 7, 2010.

Personnel Security Clearances: An Outcome-Focused Strategy and Comprehensive Reporting of Timeliness and Quality Would Provide Greater Visibility over the Clearance Process. GAO-10-117T. Washington, D.C.: October 1, 2009.

Personnel Security Clearances: Progress Has Been Made to Reduce Delays but Further Actions Are Needed to Enhance Quality and Sustain Reform Efforts. GAO-09-684T. Washington, D.C.: September 15, 2009.

Personnel Security Clearances: An Outcome-Focused Strategy Is Needed to Guide Implementation of the Reformed Clearance Process. GAO-09-488. Washington, D.C.: May 19, 2009.

DOD Personnel Clearances: Comprehensive Timeliness Reporting, Complete Clearance Documentation, and Quality Measures Are Needed to Further Improve the Clearance Process. GAO-09-400. Washington, D.C.: May 19, 2009.

High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January 22, 2009.

DOD Personnel Clearances: Preliminary Observations about Timeliness and Quality. GAO-09-261R. Washington, D.C.: December 19, 2008.

Personnel Security Clearances: Preliminary Observations on Joint Reform Efforts to Improve the Governmentwide Clearance Eligibility Process. GAO-08-1050T. Washington, D.C.: July 30, 2008.

Personnel Clearances: Questions for the Record Regarding Security Clearance Reform. GAO-08-965R. Washington, D.C.: July 14, 2008.

Personnel Clearances: Key Factors for Reforming the Security Clearance Process. GAO-08-776T. Washington, D.C.: May 22, 2008.

Employee Security: Implementation of Identification Cards and DOD’s Personnel Security Clearance Program Need Improvement. GAO-08-551T. Washington, D.C.: April 9, 2008.

DOD Personnel Clearances: Questions for the Record Related to the Quality and Timeliness of Clearances. GAO-08-580R. Washington D.C.: March 25, 2008.

DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts to Improve Clearance Processes for Industry Personnel. GAO-08-470T. Washington, D.C.: February 12, 2008.

Personnel Clearances: Key Factors to Consider in Efforts to Reform Security Clearance Processes. GAO-08-352T. Washington, D.C.: February 27, 2008.

DOD Personnel Clearances: Improved Annual Reporting Would Enable More Informed Congressional Oversight. GAO-08-350. Washington, D.C.: February 13, 2008.

DOD Personnel Clearances: Delays and Inadequate Documentation Found for Industry Personnel. GAO-07-842T. Washington, D.C.: May 17, 2007.

High Risk Series: An Update. GAO-07-310. Washington, D.C.: January 2007.

DOD Personnel Clearances: Additional OMB Actions Are Needed to Improve the Security Clearance Process. GAO-06-1070. Washington, D.C.: September 28, 2006.

DOD Personnel Clearances: 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.

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.

DOD Personnel Clearances: Some Progress Has Been Made but Hurdles Remain to Overcome the Challenges That Led to GAO’s High-Risk Designation. GAO-05-842T. Washington, D.C.: June 28, 2005.

High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January 2005.