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, and they are the three phases that were the primary focus of the findings in this testimony. At the time of our September 2006 report, our independent analysis of timeliness data showed that industry personnel contracted to work for the federal government waited more than 1 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 clearances. We found delays in all phases of the clearance process that we examined, and government statistics did not account for the full extent of the delays. Delays in the clearance process may cost money and pose threats to national security (see table 1). As table 1 shows, industry personnel granted eligibility for top secret clearances from DISCO from January to February 2006 waited an average of 446 days for their initial clearances or 545 days for their clearance updates. DOD may, however, have issued interim clearances to some of these industry personnel, which might have allowed them to begin work before they received their final clearances. IRTPA requires that beginning in December 2006, 80 percent of clearances be completed in an average of 120 days. Delays were found in each phase of the clearance process that we examined: Application submission. The application-submission phase of the clearance process took an average of 111 days for the initial clearances that DISCO adjudicated in January and February 2006 (see table 1). 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. 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 government plan for improving the clearance process noted that “investigation submission” (i.e., application submission) is to be completed within an average of 14 calendar days or less. Therefore, the 111 days taken for the application-submission phase was nearly 100 more days on average than allocated. Several factors contributed to the amount of time we observed in the application- submission phase, including rejecting applications multiple times because of inaccurate information (as reported in an April 2006 DOD Office of Inspector General report); multiple completeness reviews—the corporate facility security officer, DISCO adjudicators, and OPM staff; and manually entering data from paper applications if eQIP was not used. Investigation. Investigations for the initial top secret clearances of industry personnel adjudicated in January and February 2006 took an average of 286 days, compared to OMB’s 180-day goal for that period (see table 1). During the same period, investigations for top secret clearance updates or “reinvestigations” took an average of 419 days, almost one and a half times as long as the initial investigations (no goal is given for clearance updates or reinvestigations). The mandated February 2007 OMB report to Congress noted that “Reinvestigation timeliness has not been addressed, because the improvement effort focused on individuals for whom initial security clearances are required to perform work.” Our September 2006 report identified many factors that inhibited the speed with which OPM can deliver investigative reports to DISCO and other adjudication facilities. Those causes included backlogged cases that prevent the prompt start of work on new cases, the relative inexperience of the investigative workforce, slowness in developing the capability to investigate overseas leads, and difficulty obtaining access to data in governmental records. Adjudication. DISCO adjudicators took an average of 39 days to grant initial clearance eligibility to the industry personnel in our population (see table 1). 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. IRTPA requires that at least 80 percent of the adjudications made from December 2006 through December 2009 be completed within an average of 30 days. As of June 2006, DISCO reported that it had adjudicated 82 percent of its initial top secret clearances within 30 days. Delays in any phase of the clearance process cost money and threaten national security. Delays in completing initial security clearances may have a negative economic impact on the costs of performing classified work within or for the U.S. government. For example, in a May 2006 congressional hearing, a representative of a technology association testified that retaining qualified personnel resulted in salary premiums as high as 25 percent for current clearance holders. Delays in completing clearance updates can have serious but different negative consequences than those stemming from delays in completing initial clearance-eligibility determinations. In 1999, the Joint Security Commission reported that delays in initiating reinvestigations 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. The statistics that OMB and OPM have provided to Congress on the timeliness of the personnel security clearance process do not convey the full magnitude of the investigation-related delays facing the government. While our September 2006 report noted additional problems with the transparency of the timeliness statistics, I will review our concerns about five such issues: (1) limited information on reinvestigations for clearance updating, (2) not counting the total number of days to finish the application-submission phase, (3) shifting some investigation-related days to the adjudication phase or not counting them, (4) not counting the total number of days to complete closed pending cases, and (5) not counting the total number of days to complete investigations sent back for rework. Limited information on reinvestigations for clearance updating. In its mandated February 2007 report to Congress, OMB acknowledged that “reinvestigation timeliness has not been addressed,” but the findings from our population of industry personnel (obtained using DOD’s, instead of OPM’s, database to assess timeliness) indicated that clearance update reinvestigations took about one and a half times as long as the initial investigations. The absence of timeliness information on clearance update reinvestigations 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 reinvestigations and thereby increase the risk of unauthorized disclosure of classified information. Not counting all days to finish the application-submission phase. OMB’s February 2007 report noted that its statistics do not include “the time to hand-off applications to the investigative agency.” The gray section of the application-submission phase in table 1 shows some of the activities that were not counted when we examined January and February 2006 clearance documentation for industry personnel. These activities could be included in timeliness measurements 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 investigation phase. Shifting some investigation-related days to the adjudication phase or not counting them. In our September 2006 report, we raised concerns about how the time to complete the adjudication phase was measured. The activities in the gray section of the adjudication phase in table 1 show that the government’s procedures for measuring the time required for the adjudication phase include tasks that occur before adjudicators actually receive the investigative reports from OPM. More recently, OMB’s February 2007 report to Congress noted that its timeliness statistics do not include “the time to … hand-off investigation files to the adjudicative agency” and estimated this handling and mailing time at up to 15 days. Not counting all days for closed pending cases. OPM’s May 2006 testimony before Congress did not indicate whether the timeliness 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 investigation phase of the clearance process. According to OPM, from February 20, 2005, through 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 require to make their clearance-eligibility determinations. Not counting all days when inadequate investigations are returned.