DOD Personnel Clearances
Additional OMB Actions Are Needed to Improve the Security Clearance Process Gao ID: GAO-06-1070 September 28, 2006The 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.
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.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-06-1070, DOD Personnel Clearances: Additional OMB Actions Are Needed to Improve the Security Clearance Process
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
September 2006:
DOD Personnel Clearances:
Additional OMB Actions Are Needed to Improve the Security Clearance
Process:
GAO-06-1070:
GAO Highlights:
Highlights of GAO-06-1070, a report to congressional requesters
Why GAO Did This Study:
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. You 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.
What GAO Found:
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.
What GAO Recommends:
To improve the timeliness and completeness of investigations and
adjudications, GAO is making several recommendations to OMB. OMB did
not take exception to any of GAO‘s recommendations. OMB, DOD, and OPM
each provided agency comments.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-1070].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Derek B. Stewart at (202)
512-5559 or stewartd@gao.gov.
[End of Section]
Contents:
Letter:
Results in Brief:
Background:
Determining Top Secret Clearances for Industry Personnel Averaged More
than One Year and Government Statistics Did Not Portray All Delays:
OPM Delivered Incomplete Investigative Reports and DISCO Adjudicated
Cases Did Not Document All Clearance-determination Considerations:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Criteria for Determining Clearance Eligibility:
Appendix III: Comments from the Office of Management and Budget:
Appendix IV: Comments from the Department of Defense:
Appendix V: Comments from the Office of Personnel Management:
Appendix VI: Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Information Gathered in Conducting an Investigation to
Determine Eligibility for a Security Clearance:
Table 2: Time Required to Grant Eligibility for a Top Secret Clearance
to Industry Personnel--Cases Adjudicated in January and February 2006:
Table 3: Statistics on the Timeliness of Initial Investigations that
OPM Provided in Its Testimony Statement to Congress on May 17, 2006:
Table 4: List of Organizations Contacted to Obtain Information Related
to the Timeliness and Completeness of Investigations and Adjudications:
Figures:
Figure 1: Six Phases in the Personnel Security Clearance Process:
Figure 2: Number of OPM-prepared Investigative Reports Missing at Least
One Piece of Documentation for 12 of the 14 Types of Information--Cases
Adjudicated in January and February 2006:
Figure 3: Number of Deficient Areas in Each OPM-prepared Investigative
Report--Cases Adjudicated in January and February 2006:
Figure 4: Number of OPM-prepared Investigative Reports with at Least
One Unresolved Issue by Investigative Area--Cases Adjudicated in
January and February 2006:
Figure 5: Number of DISCO-prepared Adjudicative Reports that Did Not
Document Issues Specified in Adjudicative Guidelines in the Presence of
Adverse Information, Cases Adjudicated in January and February 2006:
Abbreviations:
DISCO: Defense Industrial Security Clearance Office:
DOD: Department of Defense:
DOHA: Defense Office of Hearings and Appeals:
e-QIP: Electronic Questionnaires for Investigations Processing:
IRTPA: Intelligence Reform and Terrorism Prevention Act:
JPAS: Joint Personnel Adjudication System:
OMB: Office of Management and Budget:
OPM: Office of Personnel Management:
OUSD(I): Office of the Under Secretary of Defense for Intelligence:
PIPS: Personnel Investigations Processing System:
United States Government Accountability Office:
Washington, DC 20548:
September 28, 2006:
Congressional Requesters:
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
[OUSD(I)] 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,[Footnote 1] 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).[Footnote 2] Now, DOD obtains nearly all of
its clearance investigations from OPM,[Footnote 3] which is currently
responsible for 90 percent of the personnel security clearance
investigations in the federal government.[Footnote 4] 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.[Footnote 5] 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[Footnote 6] (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.[Footnote 7]
Among other things, Executive Order 13381[Footnote 8] 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.[Footnote 9] 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."[Footnote 10]
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.
Results in Brief:
Our independent 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. Our analysis of 2,259 cases for
industry personnel who were granted top secret clearance eligibility in
January and February 2006 had an average of 446 days for an initial
clearance and 545 days for a clearance update. While OMB has issued a
goal that the application-submission phase of the clearance process
will take no longer than 14 days by December 17, 2006, this phase took
an average of 111 days. OPM's current procedures for measuring
application-submission timeliness do not fully capture all of the time
in the application process that starts when the application form is
submitted by the facility security officer to the federal government.
Inaccurate data that the employee provided in the application, multiple
reviews of the application, and manual entry of some application forms
are some of the causes for the extended application-submission phase.
In addition, our analyses showed that OPM took an average of 286 days
to complete the initial investigations for top secret clearances, well
in excess of the 180-day goal (no goal is given for clearance update
investigations) specified in the governmentwide plan for improving the
clearance process. Factors contributing to the slowness of completing
the investigation phase include an inexperienced investigative
workforce that has not reached its full performance level; and problems
accessing national, state, and local records. Finally, the average time
required for the adjudications for all industry personnel top secret
cases in our population was 39 days, compared to IRTPA's future
requirement that 80 percent of all cases be completed in 30 days. DOD
adjudicators have, however, noted that current procedures to measure
adjudication timeliness include 2-3 weeks for OPM to print and ship its
investigative reports, rather than delivering them electronically.
Regardless of when in the process the delays occur, the outcome is the
same--the government may incur additional costs from new industry
employees being unable to begin work promptly and increased risks to
national security because previously cleared industry employees'
backgrounds are not completed promptly to see if they still should be
eligible to hold a clearance. Our analysis of OPM-produced statistics
suggests that current methods do not fully capture and portray the time
required to obtain a clearance. For example, we have already noted that
the methods do not measure the total time for the application-
submission phase. Also, OPM-provided statistics may underrepresent the
average number of days required in the process by treating some
incomplete investigations (termed "closed pending cases") as being
fully complete and not counting all of the time when other incomplete
investigations are returned for additional investigative work. OPM's
issuance of closed pending investigations causes ambiguity in defining
and accurately estimating the backlog of overdue investigations.
Statistics that underrepresent the time that it takes for
investigations to be completed prevent congressional oversight
committees from having a fuller understanding of the government's
efforts to decrease delays in the clearance process and determining if
legislative actions are necessary.
OPM provided incomplete investigative reports to DISCO adjudicators,
and DISCO adjudicators used these reports to grant clearance
eligibility for industry personnel. In some cases, these investigative
reports contained unresolved issues such as unexplained affluence and
potential foreign influence. In our review of 50 initial investigations
for top secret clearances randomly sampled from the population used in
our timeliness analyses, we found that almost all (47 of 50) of the
sampled investigative reports were missing documentation required by
federal investigative standards. At least half of the 50 reports that
we examined did not contain the required documentation in three
investigative areas: residence, employment, and education. Moreover,
the federal standards indicate that investigations may be expanded as
necessary to resolve issues. We found at least one unresolved issue in
27 investigative reports. For example, one investigative report did not
contain additional information even though another portion of the
report briefly identified issues such as possible multiple extramarital
affairs, and financial delinquency on a loan worth several thousand
dollars. Officials from OPM's Quality Management unit reviewed 8 of our
sampled cases and confirmed that information we found to be missing
should have been included in the final investigative reports. OPM
officials suggested that the need to rapidly increase the size of the
investigative workforce and prior quality control procedures, that have
since been replaced, were some of the causes for the delivery of
incomplete investigative reports to DISCO. In our review of the
completeness of documentation in adjudicative reports, we found that
the adjudicators had not documented the missing investigative
information and did not record other information related to issues that
were present in the investigative reports. DISCO adjudicators granted
top secret clearance eligibility for 27 industry personnel whose
investigative reports contained unresolved issues without requesting
additional information or documenting in the adjudicative report that
the information was missing. DISCO officials reviewed our findings for
8 cases and indicated that documentation was missing for some of the
cases. In explaining the reasons why adjudicators might make
eligibility determinations without a full investigative report, they
noted that adjudicators weigh a variety of factors in making their risk-
based determinations. We believe that another factor is the limited
attention devoted to the assessment of completeness and other aspects
of quality. The limited assessment of quality was one of the concerns
we raised in our November 2005 assessment of the governmentwide plan
for improving the clearance process, but the plan has not been revised
to address the shortcomings that we identified. The use of incomplete
investigations and adjudications in the granting of top secret
clearance eligibility increases the risk of unauthorized disclosure of
classified information. Also, it could negatively affect efforts to
promote reciprocity that are being developed by an interagency working
group headed by OMB's Deputy Director of Management.
In order to improve the timeliness and completeness of OPM
investigations and DOD adjudications for top secret security clearance
for industry personnel, we are making a number of recommendations to
OMB's Deputy Director for Management. To improve timeliness, we
recommend that OPM and DOD fully measure and report all of the time
that transpires between when the facility security officer submits the
application to when the clearance-eligibility determination has been
provided to the customer; identify and implement information technology
solutions; and update and widely distribute the government plan for
improving the security clearance process. To improve the completeness,
we recommend that OMB require OPM and DOD to submit procedures for
eliminating the deficiencies that we identified in this review and
develop metrics for monitoring the effectiveness of the new procedures;
and in an effort to improve reciprocity, issue guidance that clarifies
when, if ever, adjudicators may use incomplete investigative reports as
the basis for granting clearance eligibility. In his comments on a
draft of this report, OMB's Deputy Director for Management did not take
exception to any of our recommendations.
Background:
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."[Footnote 11]
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.[Footnote 12] 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).
Figure 1: Six Phases in the Personnel Security Clearance Process:
[See PDF for image]
Source: GAO analysis of DOD-provided information.
[End of figure]
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.[Footnote 13] 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.
Table 1: Information Gathered in Conducting an Investigation to
Determine Eligibility for a Security Clearance:
Type of information gathered: 1. Personnel security questionnaire: The
subject's self-reported answers on a paper SF-86 form or an electronic
form;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: X;
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 2. National agency check: Data from
Federal Bureau of Investigation, military records, and other agencies
as required;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: X;
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 3. Credit check: Data from credit bureaus
where the subject lived/worked/attended school for at least 6 months;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: X;
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 4. Local agency checks: Data from law
enforcement agencies where the subject lived/worked/attended school
during the past 10 years or--in the case of reinvestigations--since the
last security clearance investigation;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: X;
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 5. Date and place of birth: Corroboration
of information supplied on the personnel security questionnaire;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: X;
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: [Empty].
Type of information gathered: 6. Citizenship: For individuals born
outside of the United States, verification of U.S. citizenship directly
from the appropriate registration authority;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: [Empty].
Type of information gathered: 7. Education: Verification of most recent
or significant claimed attendance, degree, or diploma;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 8. Employment: Review of employment
records and interviews with workplace references, such as supervisors
and coworkers;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 9. References: Data from interviews with
subject-identified and investigator-developed leads;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 10. National agency check for spouse or
cohabitant: National agency check without fingerprint;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 11. Former spouse: Data from interview(s)
conducted with spouse(s) divorced within the last 10 years or since the
last investigation or reinvestigation;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 12. Neighborhoods: Interviews with
neighbors and verification of residence through records check;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 13. Public records: Verification of
issues, such as bankruptcy, divorce, and criminal and civil court
cases;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Type of information gathered: 14. Subject interview: Collection of
relevant data, resolution of significant inconsistencies, or both;
Type of security clearance and investigation: Confidential or secret:
Initial investigation or reinvestigation: [Empty];
Type of security clearance and investigation: Top secret: Initial
investigation: X;
Type of security clearance and investigation: Top secret:
Reinvestigation: X.
Source: DOD and OPM.
[End of table]
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.
Determining Top Secret Clearances for Industry Personnel Averaged More
than One Year and Government Statistics Did Not Portray All Delays:
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.
Delays in the Application-Submission and Investigation Phases Are
Caused by Many Factors:
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.[Footnote 14] 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.[Footnote 15] 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.
Lengthy Application-Submission Phase Lacks Transparency:
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.[Footnote 16] 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.
Table 2: Time Required to Grant Eligibility for a Top Secret Clearance
to Industry Personnel--Cases Adjudicated in January and February 2006:
Total clearance process: Clearance Average:
type: Initial;
days[B]: 466;
Type: Update;
Days[B]: 545;
Type: All;
Days: 471;
Phases of security clearance process [A]: 2. Application submission:
Average days: Initial: 111;
Average Days: Update: 81;
Average days: All: 103;
Phases of security clearance process [A]: 3. Investigation: Average
days: Initial: 286;
Average Days: Update: 419;
Average Days: All: 320;
Phases of security clearance process [A]: 4. Adjudication: Average
days: Initial: 39;
Average Days: Update: 36;
Average Days: All: 38.
Example tasks and decisions required in each phase;
Phases of security clearance process [A]: 2. Application submission:
* Subject signs and dates the application;
* Facility security officer checks application materials for
completeness and accuracy, and forwards them to DISCO after any
applicable changes;
* DISCO adjudicator reviews materials for completeness and other
concerns, and returns deficient materials to the facility security
officer for further work;
* If the application materials are approved, DISCO adjudicators
determine whether the applicant is eligible for an interim clearance;
* DISCO then forwards the completed application to OPM to begin the
investigation;
* OPM reviews the application for completeness and other concerns and
returns deficient materials to DISCO for further work;
Phases of security clearance process [A]: 3. Investigation:
* If application is not submitted via e-QIP, OPM key-enters information
for the application into its investigative database;
* OPM schedules the investigation, assigning the investigation to its
federal investigative workforce or one of its investigations
contractors;
* Investigators gather the types of information identified earlier in
table 1 to produce an investigative report;
* OPM's PIPS database obtains a variety of electronic information that
is available via government databases;
* Once the investigative work has been completed, OPM checks the
investigative report for completeness before sending the report to an
adjudication facility;
Phases of security clearance process [A]: 4. Adjudication:
* OPM prints a paper copy of the investigative report;
* OPM ships the paper copies to adjudication facilities if agencies
choose or cannot get it electronically;
* DISCO adjudicator reviews the information in the investigative
report;
* DISCO adjudicator determines if industry employee is eligible for a
clearance[C].
Source: GAO analysis of OPM and DOD information.
[A] The phases referred to here are based on figure 1 provided earlier.
[B] The average days for the phases do not sum to the average days for
the total clearance process because the number of applicable cases
varies for each calculation. See app. I for details.
[C] Additional time may be needed in this phase if DISCO adjudicators
identify major security issues in the investigative report. Such cases
may be submitted to DOHA for the clearance eligibility determination.
[End of table]
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.
Investigative Phase Took Longer Than the Goal Specified:
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.[Footnote 17]
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.[Footnote 18] 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.[Footnote 19] 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.[Footnote 20] 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.
DISCO Adjudications May Have Achieved the IRTPA Timeliness Requirement:
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).[Footnote 21] 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.
Delays in Clearance Process Cost Money and Threaten National Security:
In 2004, we outlined unnecessary costs and threats to national security
that result from delays in determining clearance eligibility.[Footnote
22] 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.[Footnote 23] 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.[Footnote 24] 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.[Footnote 25]
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.[Footnote 26]
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.[Footnote 27] 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.[Footnote 28]
OPM's Timeliness Reporting Does Not Convey Full Magnitude of Delays:
The timeliness statistics that OPM[Footnote 29] 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).[Footnote 30] 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.
Table 3: Statistics on the Timeliness of Initial Investigations that
OPM Provided in Its Testimony Statement to Congress on May 17, 2006:
Clearance (and type of investigation): Top secret clearance (single
scope background investigation): Priority;
June 2005: N: 1,168;
June 2005: Average days: 58;
October 2005: N: 1,170;
October 2005: Average days: 38;
April 2006: N: 692;
April 2006: Average days: 53.
Clearance (and type of investigation): Top secret clearance (single
scope background investigation): All;
June 2005: N: 8,430;
June 2005: Average days: 284;
October 2005: N: 8,589;
October 2005: Average days: 231;
April 2006: N: 5,751;
April 2006: Average days: 171.
Clearance (and type of investigation): Secret and confidential
clearances (national agency checks with law check and credit):
Priority;
June 2005: N: 827;
June 2005: Average days: 95;
October 2005: N: 908;
October 2005: Average days: 53;
April 2006: N: 922;
April 2006: Average days: 64.
Clearance (and type of investigation): Secret and confidential
clearances (national agency checks with law check and credit): All;
June 2005: N: 34,727;
June 2005: Average days: 163;
October 2005: N: 33,521;
October 2005: Average days: 134;
April 2006: N: 32,491;
April 2006: Average days: 145.
Source: OPM.
Note: OPM extracted the above information from their Personnel
Investigations Processing System (PIPS). In our review, we found that
some entries for the investigations start date were inaccurate.
[End of table]
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.
OPM Delivered Incomplete Investigative Reports and DISCO Adjudicated
Cases Did Not Document All Clearance-determination Considerations:
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.
Almost All of the Sampled Investigative Reports Were Incomplete:
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.[Footnote 31] The requirements for
gathering these types of information were identified in federal
investigative standards published about a decade ago.[Footnote 32] 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.
Figure 2: Number of OPM-prepared Investigative Reports Missing at Least
One Piece of Documentation for 12 of the 14 Types[A] of Information--
Cases Adjudicated in January and February 2006:
[See PDF for image]
Source: GAO analysis of OPM investigative reports.
[A] The federal investigative standards and OPM's Investigator's
Handbook identify 13 investigative areas that require documentation and
also require that the investigation forms be included in the
investigative report. Some reports were missing one or more pieces of
documentation for at least one investigative area (e.g., three of the
required 10 employment interviews for a subject with five jobs), and
other reports were missing documentation in multiple investigative
areas (e.g., both residence and employment information). Two of the
types of information--financial records and subject interview--were
included in all 50 cases we examined.
[End of figure]
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).
Figure 3: Number of Deficient Areas in Each OPM-prepared Investigative
Report--Cases Adjudicated in January and February 2006A:
[See PDF for image]
Source: GAO analysis of OPM investigative reports.
[A] Some reports contained multiple deficiencies in a given
investigative area.
[End of figure]
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.[Footnote 33]
* 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.[Footnote 34]
* 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).
Figure 4: Number of OPM-prepared Investigative Reports with at Least
One Unresolved Issue by Investigative Area--Cases Adjudicated in
January and February 2006:
[See PDF for image]
Source: GAO analysis of OPM investigative reports.
[End of figure]
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.
DISCO Adjudicators Granted Top Secret Clearance Eligibility for Cases
with Missing Information:
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.[Footnote 35] 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.[Footnote 36] 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.
Figure 5: Number of DISCO-prepared Adjudicative Reports that Did Not
Document Issues Specified in Adjudicative Guidelines in the Presence of
Adverse Information, Cases Adjudicated in January and February 2006:
[See PDF for image]
Source: GAO analysis of DISCO adjudicative reports.
[End of figure]
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.
Delivery and Use of Incomplete Investigations Increase Risks to
National Security and Reciprocity:
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,[Footnote 37] 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.
Conclusions:
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.
Recommendations for Executive Action:
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.
Agency Comments:
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.
Office of Management and Budget:
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.
Department of Defense:
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.
Office of Personnel Management:
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 [Hyperlink, 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.
Signed by:
Derek B. Stewart:
Director, Defense Capabilities and Management:
List of Congressional Requesters:
The Honorable Susan M. Collins:
Chairman:
The Honorable Joseph I. Lieberman:
Ranking Minority Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable George V. Voinovich:
Chairman:
The Honorable Daniel K. Akaka:
Ranking Minority Member:
Subcommittee on Oversight of Government Management, the Federal
Workforce, and the District of Columbia:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Barbara A. Mikulski:
United States Senate:
The Honorable Tom Davis:
Chairman:
Committee on Government Reform:
House of Representatives:
The Honorable Christopher Shays:
Chairman:
Subcommittee on National Security, Emerging Threats and International
Relations:
Committee on Government Reform:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
Scope:
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.
Methodology:
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 [OUSD(I)] 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.
Table 4: List of Organizations Contacted to Obtain Information Related
to the Timeliness and Completeness of Investigations and Adjudications:
DOD adjudication facilities:
* Air Force Central Adjudication Facility, Bolling AFB, Washington, D.C.
* Army Central Adjudication Facility, Fort George Meade, Maryland;
* Defense Intelligence Agency, Central Adjudication Facility,
Arlington, Virginia;
* Defense Industrial Security Clearance Office, Columbus, Ohio;
* Defense Office of Hearings and Appeals, Columbus, Ohio;
* Navy Central Adjudication Facility, Washington, D.C.;
* National Security Agency Central Adjudication Facility, Linthicum,
Maryland;
* Washington Headquarters Services, Consolidated Adjudications
Facility, Arlington, Virginia;
Other governmental agencies and organizations:
* Defense Security Service, Headquarters, Alexandria, Virginia;
* Defense Security Service Academy, Linthicum, Maryland;
* Information Security Oversight Office, Washington, D.C.;
* National Industrial Security Program Policy Advisory Committee,
Washington, D.C.;
* DOD‘s Personnel Security Research Center, Monterey, California;
Investigative contractors:
* CACI International Inc., Arlington, Virginia;
* Kroll Inc., New York, New York;
* ManTech, Fairfax, Virginia;
* System Application and Technologies, Inc., Landover, Maryland;
* USIS, Falls Church, Virginia;
Investigator associations:
* Association of Certified Background Investigators, LaPlata, Maryland;
* American Federal Contract Investigators Association, Oceanside,
California;
Industry associations:
* The Armed Forces Communications and Electronics Association, Fairfax,
Virginia;
* Aerospace Industries Association, Arlington, Virginia;
* Contract Services Association, Arlington, Virginia;
* Information Technology Association of America, Arlington, Virginia;
* Intelligence & National Security Alliance, Annapolis Junction,
Maryland;
* National Defense Industrial Association, Arlington, Virginia;
Source: GAO.
[End of table]
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.
[End of section]
Appendix II: Criteria for Determining Clearance Eligibility:
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;
* sexual behavior;
* personal conduct, such as deliberately concealing or falsifying
relevant facts when completing a security questionnaire;
* financial considerations;
* alcohol consumption;
* drug involvement;
* emotional, mental, and personality disorders;
* criminal conduct;
* security violations;
* outside activities, such as providing service to or being employed by
a foreign country; and:
* 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.
[End of section]
Appendix III: Comments from the Office of Management and Budget:
Executive Office Of The President:
Office Of Management And Budget:
Washington, D. C. 20503:
Deputy Director For Management:
SEP 15 2006:
Mr. Derek B. Stewart Director:
Defense Capabilities and Management Government Accountability Office
Washington, DC 20548:
Dear Mr. Stewart:
Thank you for the opportunity to review the draft report, DOD Personnel
Clearances: Additional OMB Actions are Needed to Improve the Security
Clearance Process (GAO-06-1070). As you know, all affected agencies are
working diligently to fix the government's security clearance process
because all of them fully understand the impact of the current
unsatisfactory process on performance, cost, and most importantly,
security.
While I may disagree with some of the specific statistics quoted in the
report, I certainly agree that in early 2006, when agencies were just
fully launching their reform efforts, we were a long way away from
accomplishing our December 2006 goals.
Because of the scope of the longstanding problems associated with the
security clearance process, the initial focus of the Administration's
improvement efforts are with initial clearances, including contractor
clearances. I agree that the eventual focus of our improvement efforts
will also include the timeliness and quality of both initial and
updated clearances.
I agree with the report's conclusion that agencies must identify and
implement new investigative and adjudicative solutions to improve the
quality and timeliness of background investigations. Consistent with
this recommendation, this summer the Security Clearance Work Group
established a subcommittee, chaired by the Office of the Director of
National Intelligence, to explore ways to do just that.
Agencies involved in this security clearance improvement effort set
aggressive goals and targets. I agree that we should always be trying
to improve the way we measure our progress. The strategic plan
developed in the fall of 2005 is still valid and valuable, but in 2007,
we will ensure it is current and suitably aggressive.
The quality of background investigations and security clearance
adjudications is of paramount importance. The members of the Security
Clearance Working Group are providing a venue for agencies to
collaborate on and improve security clearance adjudications. However,
as a result of your report, I will ask the National Security Council's
Personnel Security Working Group to review existing adjudication
guidelines to ensure it is clear when, if ever, an adjudicator may use
incomplete investigative reports when deciding whether to grant a
security clearance.
Once again, thank you for the opportunity to review this report.
Sincerely,
Signed by:
Clay Johnson III:
[End of section]
Appendix IV: Comments from the Department of Defense:
Office Of The Under Secretary Of Defense:
5000 Defense Pentagon:
Washington, DC 20301-5000:
Intelligence:
SEP 12 2006:
Mr. Derek Stewart, Director:
Defense Capabilities and Management:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Mr. Stewart:
This is the Department of Defense (DoD) response to the GAO draft
report, "DoD Personnel Clearances: Additional OMB Actions Are Needed to
Improve the Security Clearance Process," dated August 30, 2006 (GAO
Code 350734/GAO-06-1070)."
I concur with the Recommendations for Executive Action. Please pass to
your people my appreciation for the thorough and professional manner in
which they conducted this audit.
Recent improvements, to include submission of all requests for
investigation electronically, and programming of our internal system to
facilitate documentation of adjudication decisions should decrease case
completion time and improve confidence in our adjudicative decisions.
I agree fully that adjudicatively significant issues must be returned
to the Office of Personnel Management (OPM) for further investigation.
Returning an investigation to OPM, however, adds significant time to
the clearance process. When the unresolved issue appears to be of minor
importance, I believe a risk management adjudication may be prudent.
Patchwork fixes will not solve the fundamental problem that our current
process takes too long, costs too much, and leaves us with a product of
uncertain quality. DoD is working on a new process that relies on
validated electronic data sources and tailored investigations. I
solicit your support as we acquaint the Federal personnel security
community with this process.
Sincerely,
Signed by:
Robert Andrews:
Deputy Under Secretary of Defense:
(Counterintelligence and Security):
[End of section]
Appendix V: Comments from the Office of Personnel Management:
United States Office Of Personnel Management:
Washington, DC 20415:
The Director:
September 13, 2006:
Mr. Derek B. Stewart:
Director, Defense Capabilities and Management:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Stewart:
I appreciate the opportunity to respond to the draft audit report
entitled DOD Personnel Clearances Additional OMB Actions Are Needed to
Improve the Security Clearance Process, GAO-06-1070. While I fully
support the intent of the report, I am concerned about the number of
inaccurate facts reported and upon which you have based your findings.
There are allegations throughout the GAO report that OPM's data is
incomplete and inaccurate. Conclusions were drawn based on a comparison
of the data extracted from OPM's Personnel Investigations Processing
System (PIPS) and the Department of Defense's (DOD) Joint Personnel
Adjudication System (JPAS), and the data OPM reported to OMB and
Congress. Throughout your audit, we responded to many requests for
statistical data. The data was extracted from our PIPS and based on the
timeliness measurements we use for the Intelligence Reform and
Terrorism Prevention Act (IRTPA). The measurements we use differ from
the data reported in JPAS. This does not mean our data is incorrect or
inaccurate, only that a fair comparison cannot be made between PIPS and
JPAS data.
In addition, OPM routinely provides statistical data on the overall
investigation timeliness from beginning to full completion, as well as
the timeliness from beginning to the point where OPM has completed all
items under our direct control via the Closed Pending process. These
time tracks are intended to represent processes internal and external
to OPM, and the differences are clearly identified in our reports and
presentations.
The report suggests that stakeholders and decision makers are limited
in their ability to address delays in the security clearance process
because of incomplete timeliness data. The data OPM reports quarterly
to OMB and our customer agencies provides complete timeliness data for
each phase of the investigative process: submissions, investigations,
and adjudications. Although we do not account for the timeliness of
multiple submissions, we report the percent of case papers rejected by
OPM for being incomplete or missing required information. We also
report on the timeliness and pending workloads of our third party
record providers. We reported similar data in our testimonies before
Congress. Therefore, we feel stakeholders and decision makers have the
most comprehensive data possible to understand and address the delays
in the security clearance process.
The GAO report does not take into consideration the events that
occurred during the evaluation period. These are important to note
because they impacted on case timeliness and our ability to ensure a
quality product was sent to the agency.
The study reviewed cases that were adjudicated in January and February
2006. On average, these cases took 446 days for initial clearances and
545 days for clearance updates. Based on these time frames, the cases
reviewed included investigations that were initially processed by the
Defense Security Service (DSS) prior to their transfer to OPM. Although
the investigations were closed after the transfer was completed, the
summary review of these investigations' content was also completed by
staff that transferred from DSS. We recognized early in the transfer
process that DSS and OPM did not have a consistent interpretation of
coverage requirements. Significant training for both field agents and
quality review staff was completed to standardize the scope and content
of the investigations performed by OPM. 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.
The report suggests the delays in the investigative process show the
fragmented approach the government has taken to addressing the
clearance problems. Although we might have agreed with these
conclusions prior to the IRTPA, it discounts the impact of the IRTPA
and the efforts the government has made to correct problems that been
identified for decades. OMB, OPM, and the larger security granting
agencies finalized the Plan for Improving the Personnel Security
Clearance Process in November 2005. The Plan addresses each phase of
the security clearance process and accounts for the delays your report
identified, and lays out a framework of responsibilities across
government. As our third quarter report for FY2006 shows, we are making
significant progress in all areas of the security clearance process.
Our additional comments concerning the draft report are enclosed for
your review. In general there are two significant issues that are not
addressed. First, timeliness of investigations is largely based the
calculation for average number of days to complete a case.
Unfortunately, the process of clearing the longstanding backlog means
that older cases are being completed which will skew the average
noticeably. Second, the inability of agencies to accurately predict
their workloads has been a longstanding problem as it does not allow
FISD to staff appropriately. This is the single biggest cause of delays
and backlogs, and has prompted OMB to require a more careful workload
projection process. These two issues are major factors affecting the
timeliness of investigations and should be addressed more directly.
I would welcome the opportunity to meet with your team to review all of
the concerns we have identified in the draft report prior to the
release of the final report. It would serve as a more useful management
tool for both OPM and GAO to have a balanced report that clearly
reflects the progress that has been made.
Sincerely,
Signed by:
Linda M. Springer:
Director:
Enclosure:
[End of section]
Appendix VI: Contact and Staff Acknowledgments:
GAO Contact:
Derek B. Stewart (202) 512-5559 or stewartd@gao.gov:
Acknowledgments:
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.
[End of section]
Related GAO Products:
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.
FOOTNOTES
[1] DOD, National Industrial Security Program: Operating Manual, DOD
5220.22-M (Feb. 28, 2006) notes the Secretary of Defense has entered
into agreements with 23 departments and agencies listed below for the
purpose of rendering industrial security services. This delegation of
authority is contained in an exchange of letters between the Secretary
of Defense and the civilian official with authority to delegate
authority for the following agencies: (1) National Aeronautics and
Space Administration, (2) Department of Commerce, (3) General Services
Administration, (4) Department of State, (5) Small Business
Administration, (6) National Science Foundation, (7) Department of the
Treasury, (8) Department of Transportation, (9) Department of the
Interior, (10) Department of Agriculture, (11) Department of Labor,
(12) Environmental Protection Agency, (13) Department of Justice, (14)
Federal Reserve System, (15) Government Accountability Office, (16)
U.S. Trade Representative, (17) U.S. International Trade Commission,
(18) U.S. Agency for International Development, (19) Nuclear Regulatory
Commission, (20) Department of Education, (21) Department of Health and
Human Services, (22) Department of Homeland Security, and (23) Federal
Communications Commission.
[2] According to OMB officials, 1,800 authorized spaces were
transferred from DOD to OPM. Of which, 1,578 former DOD employees were
transferred. Of these, 1,301 were investigators.
[3] Currently, three DOD agencies (National Security Agency, Defense
Intelligence Agency, and the National Reconnaissance Office) have
waivers from DOD that allow them to contract for their own personnel
security clearance investigations.
[4] In GAO, 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), we listed,
as identified by the then Deputy Associate Director of OPM's Center for
Federal Investigative Services, the departments/agencies having
statutory or delegated authority to conduct background investigations.
Those departments/agencies are the Central Intelligence Agency;
Department of State; Department of the Treasury; Internal Revenue
Service; Bureau of Engraving and Printing; Federal Bureau of
Investigation; National Security Agency; U.S. Agency for International
Development; Department of Homeland Security; Bureau of Customs and
Border Protection; U.S. Secret Service; Small Business Administration;
Broadcasting Board of Governors; Department of Justice--Bureau of
Alcohol, Tobacco, Firearms, and Explosives; U.S. Postal Service;
Tennessee Valley Authority; National Reconnaissance Office; and Peace
Corps. Even though these agencies have authority to conduct their own
investigations, some of them request that OPM conduct all or part of
their investigations.
[5] GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.:
January 2005).
[6] Pub. L. No. 108-458.
[7] 50 U.S.C. § 435b(g), Reduction in Length of Personnel Security
Clearance Process (Dec. 17, 2004).
[8] The White House, Executive Order 13381, Strengthening Processes
Relating to Determining Eligibility for Access to Classified National
Security Information (June 27, 2005). On June 29, 2006, the executive
order was extended until July 1, 2007.
[9] GAO, DOD Personnel: More Consistency Needed in Determining
Eligibility for Top Secret Security Clearances, GAO-01-465 (Washington,
D.C.: Apr. 18, 2001); and GAO, DOD Personnel: Inadequate Personnel
Security Investigations Pose National Security Risks, GAO/NSIAD-00-12
(Washington, D.C.: Oct. 27, 1999).
[10] OMB, Plan for Improving the Personnel Security Clearance Process
(November 2005).
[11] 5 C.F.R. §1312.4, Classification of National Security Information
(2006).
[12] DOD Directive 5200.2, DOD Personnel Security Program (Apr. 9,
1999), establishes policy and procedures for granting DOD military,
civilian, and industry personnel access to classified information.
Additionally, DOD Regulation 5200.2-R, DOD Personnel Security Program
(January 1987), establishes DOD personnel security policies and
procedures; sets forth standards, criteria, and guidelines upon which
personnel security determinations shall be based; prescribes the types
and scopes of personnel security investigations required; details the
evaluation and adverse action procedures by which personnel security
determinations shall be made; and assigns overall program management
responsibilities. The policies and procedures for granting industry
personnel security clearances and adjudicative procedural guidance for
appealing cases if an unfavorable clearance decision is reached also
are contained in DOD Directive 5220.6, Defense Industrial Personnel
Security Clearance Review Program (Apr. 20, 1999).
[13] The White House, "Implementation of Executive Order 12968,"
Memorandum (Washington, D.C.: Mar. 24, 1997). This memorandum includes
Investigative Standards for Background Investigations for Access to
Classified Information and Adjudicative Guidelines for Determining
Eligibility for Access to Classified Information. It approves the
adjudicative guidelines, temporary eligibility standards, and
investigative standards required by Executive Order No. 12968, Access
to Classified Information (Aug. 4, 1995).
[14] DISCO reported that it granted eligibility for 10,724 of 11,397
(94 percent) interim top secret clearance determinations and declined
interim clearances for 673, during the period from October 1, 2005,
through July 31, 2006. To grant an interim clearance, DISCO stated that
it reviews the security clearance application, performs record checks
using DOD and OPM security databases, verifies that there is no
existing clearance eligibility or investigation that would meet the
requirements of the application, and determines that the facts and
circumstances indicate that access to classified information is
consistent with the national security interests of the United States.
[15] In our analyses, we are not identifying the percentage of top
secret clearances which were completed within an average of 120 days.
Because investigations for top secret clearances require more time for
data collection than do the investigations for secret or confidential
clearances, the comparison of the overall timeliness or the
investigation time for top secret clearances only could result in
misleading conclusions about the government's ability to meet the IRTPA
requirement for all levels of clearances combined.
[16] JPAS included a field that recorded the date the personal security
questionnaire was sent to DISCO by the facility security officers.
These data were used as the starting point for our analyses.
[17] OPM's 2006 quarterly reports showed that DOD exceeded its
projected workload for top secret cases during the first and second
quarters of fiscal year 2006 by 32 and 22 percent, respectively. The
government plan established a 5 percent limit on how far agencies could
exceed their workload projections.
[18] GAO, 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).
[19] GAO, DOD Personnel Clearances: New Concerns Slow Processing of
Clearances for Industry Personnel, GAO-06-748T (Washington, D.C.: May
17, 2006).
[20] The White House, Homeland Security Presidential Directive/Hspd-12,
Policy for a Common Identification Standard for Federal Employees and
Contractors (Aug. 27, 2004).
[21] This time includes the amount of time taken to transfer
investigative reports from OPM to DISCO, since DISCO was not tracking
the transfer time during the period that GAO selected its sample.
[22] GAO, DOD Personnel Clearances: DOD Needs to Overcome Impediments
to Eliminating Backlog and Determining Its Size, GAO-04-344
(Washington, D.C.: Feb. 9, 2004).
[23] GAO, Faster Processing of DOD Personnel Security Clearances Could
Avoid Millions in Losses, GAO/GGD-81-105 (Washington, D.C.: Sept. 15,
1981).
[24] Joint Security Commission, Redefining Security: A Report to the
Secretary of Defense and the Director of Central Intelligence, Chapter
4, Personnel Security--The First and Best Defense (Washington, D.C.:
Feb. 28, 1994).
[25] Doug Wagoner, statement for the record, hearing before the
Committee on Government Reform, U.S. House of Representatives (May 17,
2006).
[26] DOD Office of the Inspector General, Human Capital: DOD Security
Clearance Process at Requesting Activities, D-2006-077 (Arlington, Va.:
Apr. 19, 2006).
[27] 5 C.F.R. § 1312.4, Classification of National Security Information
(2006).
[28] Joint Security Commission II, Report of the Joint Security
Commission II (Aug. 24, 1999), pp.5-6.
[29] As we mentioned earlier, the governmentwide plan states that
except for a limited number of programs, OMB Memorandum M-05-17
delegated OPM responsibility for the day-to-day oversight and
monitoring of security clearance investigations, including
investigations for clearance updates.
[30] OPM, Progress or More Problems: Assessing the Federal Government's
Security Clearance Process, Statement of Kathy L. Dillaman, before the
Subcommittee on Oversight of Government Management, the Federal
Workforce, and the District of Columbia, Committee on Homeland Security
and Governmental Affairs, U.S. Senate (Washington, D.C.: May 17, 2006).
[31] We reviewed the investigative reports for the presence or absence
of the documentation. Available information often did not allow a
determination of why the documentation was missing. For example,
required documentation could be missing because an investigator failed
to either perform the activity involved in gathering the information or
submit the information after it had been gathered. In either case, an
investigative report would not provide an adjudicator with all of the
information prescribed in the federal investigative standards.
[32] The White House, "Implementation of Executive Order 12968,"
Memorandum (Washington, D.C.: Mar. 24, 1997). This memorandum approves
the adjudication guidelines, temporary eligibility standards, and
investigative standards required by Executive Order 12968, Access to
Classified Information (Aug. 2, 1995). We obtained additional
information on the operations used to obtain and document investigative
information by attending OPM's 3-week investigator training and from
OPM's guidance to its investigators: OPM, Investigator's Handbook
(Draft version 5, March 2005).
[33] Investigative scope defines the time period for which
investigators are required to examine aspects of a subject's background
in each investigative area. For example, in initial investigations,
investigators are required to obtain information about all jobs of 6
months or more that took place within the 7 years prior to the date the
investigation was scheduled. While this is the minimum requirement,
instructions provided in OPM's training for new investigators
encouraged coverage of all employment during the period of interest,
noting that shorter terms of employment would probably reveal more
issues.
[34] According to OPM's Investigator's Handbook and subsequent
clarifications, two source interviews are required for each activity
listed on a subject's clearance application. Activities include the
subject's employment, education, and residence.
[35] Mitigation factors were also missing for these 22 guidelines since
an adjudicator would not mitigate an issue if the applicable
adjudicative guideline had not been documented in JPAS. We found four
other instances where a guideline was reported in JPAS, but the
mitigating factor was not indicated.
[36] The Adjudicative Desk Reference identifies the logic of a
particular security concern for each of the 13 federal adjudicative
guidelines, examples of conditions that raise a security concern, and
examples of conditions that could mitigate security concerns. DOD's
Decision Logic Table is from the Defense Security Service's 20-1-M
(April 2003) and contains guidance concerning investigation expansion
for each adjudicative guideline. Each section of the table presents one
of the 13 adjudicative guidelines and discusses the concern, the
potential disqualifying condition, and the mitigating factors that
pertain to each guideline. To identify instances of missing
documentation in an adjudicative report, we compared information in the
investigative reports to security concerns specified in these two
source documents.
[37] This committee is led by OMB's Deputy Director for Management and
is comprised of representatives from DOD, Homeland Security, Energy,
Justice, Transportation, Commerce, State, the Director of National
Intelligence, the National Security Council, and the National Archives
and Records Administration.
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