Personnel Security Clearances
Preliminary Observations on Joint Reform Efforts to Improve the Governmentwide Clearance Eligibility Process Gao ID: GAO-08-1050T July 30, 2008Over the past decade a number of requirements have been established with regard to the processing of security clearances for federal employees. The Intelligence Reform and Terrorism Prevention Act (IRTPA) of 2004 established statutory clearance requirements for the executive agencies, military departments, and intelligence community. These requirements include, among other things, milestones for the reduction in length of time to complete personnel security investigations and adjudications, reciprocity of security clearance and access determinations, the establishment of an integrated database to track investigative and adjudication information with the authorization of appropriations for its implementation, and continuous evaluation of available technology in investigations and adjudications. The most recent security clearance reform efforts include the Joint Security and Suitability Reform Team's (hereafter referred to as the joint reform team) Security and Suitability Process Reform initial report, which was issued on April 30, 2008 in response to a memorandum from the President, and the President's Executive Order 13467, which was released on June 30, 2008. The joint reform team's initial report contains a reform plan that outlines a new 7-step process for determining clearance eligibility, and the executive order establishes a Performance Accountability Council to implement that plan. The joint reform team's initial plan and the executive order reflect the collaborative efforts of several key agencies, including the Office of the Director of National Intelligence (ODNI), DOD, OPM, and the Office of Management and Budget (OMB).
The recent security clearance reform efforts, as reflected in the joint reform team's initial plan and Executive Order 13467, consist of several elements, including responsiveness to the President's direction with an initial plan that identifies several primary near-term actions to follow, input from key stakeholders, and support from and accountability of high-level leadership. First, the joint reform team's plan responds to the President's direction for an initial plan and identifies several primary near-term actions. For example, the plan states that the joint reform team will develop an automated records check capability to expedite clearance investigations. Second, the reform efforts contain input from key stakeholders. In our previous work, we have found that stakeholder involvement in strategic planning is particularly important because of complex political environments and the potential for stakeholders to disagree strongly about missions and goals. A third element, consistent with the best practices we have identified for guiding agencies undergoing cultural transformation, is that the reform efforts have the support of high-level governmentwide leadership and hold this leadership accountable to the President to achieve the reform. We have previously reported that committed, sustained leadership and persistent attention by all parties is indispensable for the successful implementation of organizational transformations, such as making lasting changes to the governmentwide security clearance reform effort. The reform plan was developed under the leadership of four senior executives--the Director of National Intelligence, the Director of OPM, the Deputy Director for Management at OMB, and the Under Secretary of Defense (Intelligence)--who are described in the plan as reform champions. The executive order identifies specific positions that are accountable, and we believe it is significant that the order established a framework for key accountable leadership before the upcoming change in administrations because the senior leadership currently occupying these positions will change with the transition of presidential administrations after the 2008 elections. Our experience has shown that successful major change management initiatives can often take at least 5 to 7 years to help create the accountability needed to ensure that the transformation initiatives are successfully completed. This length of time and the frequent turnover of political leadership in the federal government have often made it difficult to obtain the sustained attention needed to make changes in government reform efforts.
GAO-08-1050T, Personnel Security Clearances: Preliminary Observations on Joint Reform Efforts to Improve the Governmentwide Clearance Eligibility Process
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United States Government Accountability Office:
GAO:
Testimony:
Before the Subcommittee on Intelligence Community Management, House
Permanent Select Committee on Intelligence, U.S. House of
Representatives.
For Release on Delivery:
Expected at 2:30 p.m. EDT:
Wednesday, July 30, 2008:
Personnel Security Clearances:
Preliminary Observations on Joint Reform Efforts to Improve the
Governmentwide Clearance Eligibility Process:
Statement of Brenda S. Farrell, Director:
Defense Capabilities and Management:
GAO-08-1050T:
July 30, 2008:
Madam Chairwoman and Members of the Subcommittee:
Thank you for the opportunity to be here today to discuss our
preliminary observations of the federal government‘s efforts to reform
the security clearance process. Over the past several years, we have
performed extensive work and gained experience on government
transformation. The expertise gained from these efforts, coupled with
our decades of experience reviewing the DOD security clearance process,
positions GAO to help guide the governmentwide security clearance
reform efforts. [Footnote 1] Moreover, we have identified useful
practices and lessons learned from our work on transformation that
agencies could use to successfully transform their cultures. Since
January 2005, when we first placed the Department of Defense‘s (DOD)
personnel security clearance program on our list of high-risk
government programs and operations,[Footnote 2] we have testified
several times on clearance-related issues. We testified most recently
before this Subcommittee in February 2008. [Footnote 3]
We placed DOD‘s personnel security clearance program on our high-risk
list in 2005 because of a variety of long-standing problems in the
program. In the 2007 update to our high-risk report,[Footnote 4] we
described some of those problems, which included (1) delays in
completing the end-to-end clearance processing; (2) incomplete
investigative reports from the Office of Personnel Management (OPM),
the agency that supplies about 90 percent of all federal clearance
investigations, including those for DOD; and (3) the granting of some
clearances by adjudicators even though required data were missing from
the investigative reports used to make such determinations. Further,
before this Subcommittee in February 2008, we identified four factors
key to reforming the security clearance process.[Footnote 5] These
factors are (1) having a sound requirements-determination process in
place, (2) building quality into every step of the clearance process,
(3) having a valid set of metrics for evaluating efficiency and
effectiveness, and (4) providing Congress with the long-term funding
requirements of security clearance reform. I would also like to add,
however, that the security clearance reform process is evolving and a
number of noteworthy actions have been taken to improve the security
clearance process since our high-risk designation in 2005. We have
reported on and testified about these actions regularly since our
designation.
Over the past decade a number of requirements have been established
with regard to the processing of security clearances for federal
employees. The Intelligence Reform and Terrorism Prevention Act
(IRTPA)[Footnote 6] of 2004 established statutory clearance requirements
for the executive agencies, military departments, and intelligence
community. These requirements include, among other things, milestones
for the reduction in length of time to complete personnel security
investigations and adjudications, reciprocity of security clearance and
access determinations, the establishment of an integrated database to
track investigative and adjudication information with the authorization
of appropriations for its implementation, and continuous evaluation of
available technology in investigations and adjudications.
The most recent security clearance reform efforts include the Joint
Security and Suitability Reform Team‘s (hereafter referred to as the
joint reform team) Security and Suitability Process Reform initial
report, which was issued on April 30, 2008 in response to a memorandum
from the President, and the President‘s Executive Order 13467, which
was released on June 30, 2008. The joint reform team‘s initial report
contains a reform plan that outlines a new 7-step process for
determining clearance eligibility, and the executive order establishes
a Performance Accountability Council to implement that plan. The joint
reform team‘s initial plan and the executive order reflect the
collaborative efforts of several key agencies, including the Office of
the Director of National Intelligence (ODNI), DOD, OPM, and the Office
of Management and Budget (OMB).
Today, you asked us to discuss the personnel security joint reform
efforts. As requested, my statement today will address our initial
observations on (1) elements of the most recent security clearance
reform efforts and (2) the extent to which the recent reform efforts
address key factors that should be considered in efforts to reform the
security clearance process. We also identified best practices that
agencies can use to successfully transform their cultures and,
accordingly, can guide the implementation of these personnel security
clearance reform efforts. My statement is based on our preliminary
review of the joint reform team‘s initial plan, issued April 30, 2008,
the appendix to that plan, and Executive Order 13467, as well as our
prior work on security clearance processes, which included reviews of
clearance-related documents and interviews of senior officials at OMB,
DOD, and OPM. In addition, this statement is based on key practices and
implementation steps we developed from our institutional knowledge on
organizational transformation.[Footnote 7] Our preliminary review was
performed in July 2008 in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions, based on our audit
objectives. We believe that the evidence we obtained provides a
reasonable basis for our findings and conclusions based on our
objectives. We also discussed this statement with the Deputy Director
of OMB, who shared with us the progress the joint reform team has
made toward meeting timeliness goals in completing clearance
determinations. In addition, he noted that the Performance
Accountability Council, which was established in Executive Order 13467,
intends to submit a more detailed implementation plan for the reformed
security clearance process to the President in December 2008.
As you know, the Chairman of the Permanent Select Committee on
Intelligence of the U.S. House of Representatives and you, in your
capacity as Chairwoman of this Subcommittee, have also requested that
we conduct an in-depth review of ongoing security clearance reform,
assess these reform efforts relative to best practices that we have
used to evaluate other government transformation, and review the
criteria that the administration is using to assess the effectiveness
of its initiatives in this area. We have recently begun this work and
expect to fully report on our findings at a future date.
Summary:
The recent security clearance reform efforts, as reflected in the joint
reform team‘s initial plan and Executive Order 13467, consist of
several elements, including responsiveness to the President‘s direction
with an initial plan that identifies several primary near-term actions
to follow, input from key stakeholders, and support from and
accountability of high-level leadership. First, the joint reform team‘s
plan responds to the President‘s direction for an initial plan and
identifies several primary near-term actions. For example, the plan
states that the joint reform team will develop an automated records
check capability to expedite clearance investigations. Second, the
reform efforts contain input from key stakeholders. In our previous
work, we have found that stakeholder involvement in strategic planning
is particularly important because of complex political environments and
the potential for stakeholders to disagree strongly about missions and
goals. A third element, consistent with the best practices we have
identified for guiding agencies undergoing cultural transformation, is
that the reform efforts have the support of high-level governmentwide
leadership and hold this leadership accountable to the President to
achieve the reform. We have previously reported that committed,
sustained leadership and persistent attention by all parties is
indispensable for the successful implementation of organizational
transformations, such as making lasting changes to the governmentwide
security clearance reform effort. The reform plan was developed under
the leadership of four senior executives”the Director of National
Intelligence, the Director of OPM, the Deputy Director for Management
at OMB, and the Under Secretary of Defense (Intelligence)”who are
described in the plan as reform champions. The executive order
identifies specific positions that are accountable, and we believe it
is significant that the order established a framework for key
accountable leadership before the upcoming change in administrations
because the senior leadership currently occupying these positions will
change with the transition of presidential administrations after the
2008 elections. Our experience has shown that successful major change
management initiatives can often take at least 5 to 7 years to help
create the accountability needed to ensure that the transformation
initiatives are successfully completed. This length of time and the
frequent turnover of political leadership in the federal government
have often made it difficult to obtain the sustained attention needed
to make changes in government reform efforts.
Our review of the joint reform team‘s initial plan and Executive Order
13467 showed these documents begin to but do not fully address the four
factors that we identified in February 2008 as key to reforming the
security clearance process. First, the joint team‘s plan states that a
reformed security clearance process would begin with a step to validate
the need for a clearance. However, neither the plan nor the executive
order includes discrete actions for implementing a sound requirements
determination process across all of the government agencies that issue
security clearances. We previously reported that any reform effort
should address whether the quantity and level of clearances are
appropriate and include discrete actions or milestones for implementing
a sound requirements determination process. We noted that unnecessary
requirements or increases in the number or level of requested
clearances result in increased costs and investigative and adjudicative
workloads. Second, while the plan provides some information on building
quality into the clearance process, it provides limited details on how
the new automated processes will ensure quality. In February 2008, we
identified quality control and quality monitoring as key factors in a
reformed security clearance process. As we reported in September 2006,
lack of full reciprocity of clearances is an outgrowth of agencies‘
concerns over the quality of other agencies‘ investigation and
adjudication processes. Third, the reform efforts emphasize timeliness
but do not discuss the use of additional metrics that the joint reform
team and the Performance Accountability Council could use to evaluate
the performance of a reformed process. In February 2008, we noted that
the reformed clearance process should have a valid set of metrics
beyond those measuring timeliness to evaluate the efficiency and
effectiveness of the process. We believe that including metrics on both
the efficiency and effectiveness of clearance processes could add value
in current and future reform efforts as well as supply better
information for greater congressional oversight. Finally, neither the
plan nor the executive order contain information about funding
requirements, which limits its utility as a tool for decision makers.
In February 2008, we noted that the plan should provide long-term
funding requirements to implement the proposed changes. In addition
to limiting the executive branch‘s ability to compare and prioritize
the reform plan, we believe the absence of any funding requirements to
implement the reforms limits the utility of the reform efforts as a
tool for decision makers in both the executive and legislative branches
to carry out their budgetary development and oversight functions. These
factors may be addressed in a more detailed plan that OMB says it will
issue in December 2008.
Moving forward, we believe that the reform efforts could benefit from
clearly incorporating additional best practices we identified for
agencies to successfully transform their cultures. These best practices
include, among other things (1) establishing a coherent mission and
integrating strategic goals to guide the transformation, (2) focusing
on a key set of principles and priorities at the outset of the
transformation, (3) setting implementation goals and a timeline to
build momentum and show progress from day one, and (4) establishing a
communication strategy to create shared expectations and report related
progress. For example, using these practices to meet long-term IRTPA
requirements can assist in the development of a coherent mission, guide
the transformation, and focus efforts on key principles and priorities.
OMB informed us in July 2008 that the Performance Accountability
Council plans to issue a report detailing the implementation of the
reformed security clearance process in December 2008. Going forward,
incorporating these best practices could help to better ensure
successful implementation of reform efforts as the Council prepares its
December report. These practices become even more important given the
upcoming change in administrations.
Background:
In considering ways in which to reform the government‘s security
clearance process, it is helpful to note that since 1997, all agencies
have been subject to a common set of personnel security investigative
standards and adjudicative guidelines for determining whether
servicemembers, federal workers, industry personnel, and others are
eligible to receive a security clearance. [Footnote 8] Clearances are
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 cause to national security. The degree of expected damage
that unauthorized disclosure could reasonably be expected to cause is
’exceptionally grave damage“ for top secret information, ’serious
damage“ for secret information, and ’damage“ for confidential
information. [Footnote 9]
The President issued Executive Order 13381, Strengthening Processes
Relating to Determining Eligibility for Access to Classified National
Security Information in June 2005[Footnote 10] as part of the efforts
to improve the security clearance process and to implement the
statutory clearance requirements in IRTPA. Among other things, this
order tasked OMB‘s Deputy Director for Management with ensuring the
effective implementation of policy regarding appropriately uniform,
centralized, efficient, effective, timely, and reciprocal agency
functions relating to determining eligibility for access to classified
national security information. Since 2005, OMB‘s Deputy Director for
Management has taken several actions to improve the security clearance
process. These actions include establishing an interagency working
group to improve the reciprocal acceptance of clearances issued by
other agencies and taking a lead role in preparing a November 2005
strategic plan to improve the timeliness of personnel security
clearance processes governmentwide. The November 2005 strategic 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 be held accountable to the IRTPA
timeliness requirements.
In June 2007 the OMB Deputy Director”in collaboration with the Director
of National Intelligence and the Under Secretary of Defense for
Intelligence”established the joint reform team to develop a reformed
DOD and intelligence community security clearance process. [Footnote
11] The joint reform team submitted a reform plan to the President
dated April 30, 2008, which presents the design of a transformed hiring
and clearing process. The plan developed a new process for determining
clearance eligibility that involves several steps, including (1)
validating the need for a clearance, (2) an electronic application, (3)
automated records checks, (4) electronic adjudication, (5) an enhanced
subject interview, (6) an expandable focused investigation, and (7)
continuous evaluation between clearance investigations.
Since the release of the joint reform team‘s plan, the President issued
Executive Order 13467 on June 30, 2008 that lists policy requirements
to ensure an efficient, practical, reciprocal, and aligned system for
investigating and determining suitability for government employment,
contractor employee fitness, and eligibility for access to classified
information. Specifically, it establishes a Performance Accountability
Council with designated executive agents that are accountable to the
President to achieve the goals of the reform effort stated in the
order, which are ultimately to streamline the background investigation
and clearance eligibility determinations across the federal government.
The order also designates the Deputy Director for Management at OMB as
the chair of the Council, who will have the authority to designate
officials from additional agencies to serve as members, and the Deputy
Director expressed his intention to us to reach out to federal
agencies.
Reform Documents Show That Reform Efforts to Date Are Responsive to
President‘s Direction, Include Stakeholder Input, and Emphasize
Accountability:
Based on our preliminary observations, the recent security clearance
reform efforts in the joint reform team‘s plan and the June 30, 2008,
executive order contain several important elements, including
responsiveness to the President‘s direction, input from key
stakeholders, and support from and accountability of high-level
leadership. The first element of the plan is that it responds to the
President‘s direction with an initial plan that identifies several
primary near-term actions. The President issued a memorandum on
February 5, 2008, that directed the team to submit an initial reform
plan no later than April 30, 2008. As directed, the joint reform team
submitted an initial plan to the President dated April 30, 2008, which
describes several near-term actions that will be taken to transform the
security clearance process across the federal government. These actions
include (1) establishing an executive branch governance structure to
achieve the goals of reform and sustain reform momentum through the
upcoming administration transition, (2) developing and initiating
automated systems for the application, adjudication, and record
checking steps, and (3) developing an information technology strategy
to enable improvements governmentwide.
In addition, progress has already been made in implementing one of
these near-term actions. Executive Order 13467 was issued in response
to the joint reform team‘s initial plan. This order establishes a
formal structure for reform and directs changes to the oversight
structure of the agencies spearheading the reform effort. It
establishes the governance structure called for in the joint reform
team‘s plan”called the Performance Accountability Council”and holds the
council accountable to the President to achieve the goals listed in the
executive order. These goals include (1) ensuring the alignment of the
investigation and adjudication processes, (2) holding agencies
accountable for implementation of processes/procedures, (3)
establishing requirements for information technology, (4) establishing
goals and metrics and preparing annual reports on results of the
metrics, (5) overseeing development of tools/techniques for enhancing
investigations and eligibility determinations, (6) arbitrating
disparities in procedures between the executive agents, (7) ensuring
sharing of best practices, and (8) advising executive agents on
policies affecting alignment of investigations and adjudications. The
level of direction in the executive order and the establishment of a
very specific, centralized structure make this latest reform effort
stand out from past efforts.
Second, the reform efforts to date contain input from key stakeholders.
In our previous work, we found that stakeholder involvement in
strategic planning is particularly important because of complex
political environments and the potential for stakeholders to disagree
strongly about missions and goals. In a letter accompanying the joint
reform team‘s plan, OMB‘s Deputy Director for Management highlights
that the plan is the product of the collaborative efforts of several
key agencies, including the ODNI, DOD Office of the Under Secretary of
Defense (Intelligence), OPM, the Office of the Assistant to the
President for National Security Affairs, and OMB. These agencies are key
stakeholders given their various roles in government security clearance
programs and processes. Furthermore, the joint reform team was composed
of and consulted with government and industry subject matter experts.
These experts included representatives from (1) ODNI‘s Special Security
Center Director, (2) DOD‘s Personnel Security Research Center, (3)
DOD‘s Defense Security Service, (4) OPM‘s Federal Investigative
Services Division, and (5) intelligence community subject matter
experts.
Furthermore, the reform efforts also have the support of high-level
governmentwide leadership and hold this leadership accountable.
Committed, sustained, highly qualified, and inspired leadership and
persistent attention by all parties is a best practice that we have
previously identified as indispensable for the successful
implementation of organizational transformations, such as making
lasting changes to the governmentwide security clearance reform effort.
The joint reform team‘s plan was developed under the leadership of four
senior executives who are described in the plan as reform champions.
These four senior executives are the Director of National Intelligence,
the Director of OPM, the Deputy Director for Management at OMB, and the
Under Secretary of Defense (Intelligence). In February 2008, we
reported additional indicators of high-level governmentwide leadership
support in addressing problems in the security clearance process.
[Footnote 12] For example, we noted that an August 9, 2007, memorandum
from the Deputy Secretary of Defense indicates that DOD‘s clearance
program is drawing attention at the highest levels of the department.
Streamlining security clearance processes is one of the 25 DOD
transformation priorities identified in the memorandum. The leadership
involved in the development of the reform efforts is also held
accountable to the President to ensure that the reform goals are
achieved. For example, the new executive order is more directive than
reform efforts in the past decade because it assigns specific
responsibilities to the high-level leadership that it appoints to be
members of the Performance Accountability Council. The order designates
the Deputy Director of OMB as Chair of the Council, the Director of OPM
as the Suitability Executive Agent, and the Director of National
Intelligence as the Security Executive Agent. [Footnote 13] In
addition, the order states that the Council is held accountable to the
President for the implementation of reform and to achieve the reform
effort‘s goals. The order identifies the positions that are
accountable, and we believe it is significant that the order
established a framework for the involvement and accountability of key
leadership before the upcoming change in administrations because much
of the senior leadership currently occupying these positions could
change with the transition of presidential administrations after the
2008 elections. In fact, it is possible that these positions could be
vacant for a period of time or be temporarily filled during the
transition. Our experience has shown that successful major change
management initiatives in large public and private sector organizations
can often take at least 5 to 7 years to help create the accountability
needed to ensure that long-term management and transformation
initiatives are successfully completed. This length of time and the
frequent turnover of political leadership in the federal government
have often made it difficult to obtain the sustained attention needed
to make changes in other government reform efforts.
Moreover, the plan also formalizes a specific role for the intelligence
community, one of the key stakeholders in the security clearance
process. Specifically, the leadership arrangement established by the
executive order formalizes the role of the Director of National
Intelligence in the reform process as the Security Executive Agent.
Under the order, the Security Executive Agent is responsible for, among
other things, developing policies and procedures for making clearance
eligibility determinations and for ensuring governmentwide reciprocity
of clearances. Formalizing leadership roles is essential to ensuring
that the reform effort moves forward through the transition of the
administration following the 2008 presidential election. Together, the
joint reform team‘s plan and the President‘s executive order develop
and assign leadership roles and establish a formal structure that was
not previously in place and that intends to streamline the security
clearance process.
Reform Efforts Could Benefit from More Fully Incorporating Four Factors
Key to Reforming the Security Clearance Process:
Based on our preliminary analysis, while recent security clearance
reform documents begin to address key factors, the recent documents do
not yet fully address the four factors that we identified in February
2008 as key to reforming the security clearance process. First, the
joint team‘s plan mentions that a reformed security clearance process
would begin with a step to validate the need for a clearance, but does
not include discrete actions for implementing a sound requirements
determination process across all of the government agencies that issue
security clearances. Second, the reform efforts provide some
information on building quality into the clearance process, but provide
limited details on how the new automated processes will ensure quality.
Third, the reform efforts emphasize timeliness but do not discuss the
use of additional metrics that the team and stakeholders would use to
evaluate the performance of a reformed process. Finally, neither the
plan nor the executive order contain information about funding
requirements, which limits their utility as tools for decision makers.
Plan Mentions the Need for a Step to Validate the Need for a Clearance,
but Does Not Include Discrete Actions for Implementing a Sound
Requirements Determination Process:
Of the two recent reform efforts, only the joint reform team plan
mentions the need for the reformed process to begin with a step to
validate the need for a clearance, but it does not include discrete
actions for implementing a requirements determination process across
all of the government agencies that issue security clearances. The
executive order does not establish any requirements or steps for
clearance requirements determination In February 2008, we noted that
the joint reform team should address whether the numbers and levels of
clearances are appropriate, since this initial stage in the clearance
process can affect workloads and costs in other clearance stages. The
joint reform team‘s plan states that the first step in a reformed
clearance process would be to validate the need for a clearance request
against mission needs. The plan states that this step would focus on
optimizing policy, procedures, and tools before investigations are
requested and that the new clearance design would provide a process
whereby managers only submit individuals to the clearance process as
needed. The plan describes the benefits of validating needs, which
include actively managing investigation requests to potentially result
in the reduction of unnecessary investigative activity. While it is
positive that the joint reform team‘s plan begins with a step to
validate clearance needs, the plan does not include any discrete
actions or milestones for implementing a clearance need process. As we
noted in February 2008, [Footnote 14] it will be important for the
joint reform team to continue to ensure a strong requirements
determination process is a part of its reforms as it develops its plans
further.
As we noted in our testimony before this Subcommittee in February 2008,
an increase in the number or level of requested clearances increases
the investigative and adjudicative workloads. We have previously
reported that a growing percentage of all DOD requests for clearances
for industry personnel was at the top secret level. [Footnote 15] This
increase in the proportion of investigations at the top secret level
affects workloads and costs because top secret clearances must be
renewed twice as often as secret clearances (i.e., every 5 years versus
every 10 years). 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. The
doubling of the frequency along with the increased effort to
investigate and adjudicate each top secret reinvestigation adds costs
and workload for the government. [Footnote 16]
As we noted in February 2008, we are not commenting on the
appropriateness of the current numbers and levels of clearances;
instead, we are pointing out that any unnecessary clearance requests
use government resources that can be utilized for other purposes, such
as building additional quality into other clearance phases or decreasing
delays in clearance processing. Unless the new system developed by the
joint reform team includes a sound requirements process, workload and
costs may be higher than necessary.
Reform Efforts Provide Some Information on Building Quality into the
Clearance Process, but Include Limited Details on How Automated
Processes Will Ensure Quality:
The joint reform team‘s plan provides some information on building
quality into the clearance process, but it includes limited details on
how automated processes will ensure quality. In February 2008, we noted
that a key factor the government should consider as it develops a
reformed security process was the incorporation of quality control and
quality monitoring into the clearance process. The joint reform team‘s
plan includes references to quality and quality control in a number of
instances. For example, in a section in which the key features of the
reformed process are described, the plan states that relevant data
would be better used for subsequent hiring or clearing decisions,
reducing duplication of requests, and ensuring consistent quality and
standards. In addition, the joint reform team plan describes new
automated processes (e.g., electronic adjudication of cases with no
issues) that it asserts will help ensure consistency and quality in the
decision-making process. However, at this stage in the joint reform
team‘s efforts, the plan provides limited details regarding how these
new processes will ensure quality, and there is no discussion of any
quality metrics the government would monitor and report to measure the
performance of a reformed clearance process. While the executive order
calls for metrics on the implementation of reform goals, it does not
specifically discuss quality in the investigation and adjudication
processes. As we noted in February 2008, [Footnote 17] it will be
important for the joint reform team to continue to build quality and
quality reporting into a reformed clearance process as it develops its
plans further.
We have previously noted the government‘s limited attention to
reporting on quality measures in the security clearance process. In our
November 2005 testimony on the previous governmentwide strategic plan
to improve the clearance process, we noted that the strategic plan
devoted little attention to monitoring and improving the quality of the
personnel security clearance process, and that limited attention to and
reporting about quality continues. In addition, when OMB issued its
February 2007 Report of the Security Clearance Oversight Group
Consistent with Title III of the Intelligence Reform and Terrorism
Prevention Act of 2004, it documented quality with a single metric. OMB
stated that overall, less than 1 percent of all completed
investigations are returned to OPM from the adjudicating agencies for
quality deficiencies. When OMB issued its February 2008 Report of the
Security Clearance Oversight Group, it did not discuss the percentage
of completed investigations that are returned to OPM or the development
or
existence of any other metric measuring the level of quality in
security clearance processes or products. We have previously reported
that it is problematic to equate the quality of investigations with the
percentage of investigations that are returned by requesting agencies
due to incomplete case files. For example, in October 1999 and again
in our November 2005 evaluation of the governmentwide strategic plan,
we stated that the number of investigations returned for rework is not
by itself a valid indicator of quality because adjudication officials
said they were reluctant to return incomplete investigations as they
anticipated this would lead to further delays. [Footnote 18] In our
September 2006 report, we recommended that regardless of whether this
metric continues to be used, OMB‘s Deputy Director for Management
should require OPM and DOD to develop and report metrics on
investigative and adjudicative completeness and other measures of
quality. [Footnote 19] In commenting on our 2006 report, OMB‘s Deputy
Director for Management did not take exception to this recommendation,
but the joint reform team plan does not describe any new quality
measures or mention any plans to develop such measures.
In September 2006, we reported that while eliminating delays in
clearance processes is an important goal, the government cannot afford
to achieve that goal at the expense of quality.20 We additionally
reported that 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. An
interagency working group, the Security Clearance Oversight Steering
Committee, noted that agencies are reluctant to be accountable for poor
quality investigations 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.
Reform Efforts Emphasize Timeliness, but Do Not Discuss Additional
Metrics That Could Be Used to Evaluate Clearance Process Performance:
The joint reform team plan emphasizes timeliness but does not contain a
discussion of the use of additional metrics that the team and
stakeholders would use to evaluate the performance of a reformed
process. In addition, the executive order tasks the Performance
Accountability Council with establishing annual goals and metrics for
implementation of the reform effort, but not necessarily for the
processing of clearance determinations. This order also states that the
Security Executive Agent may establish guidelines for timeliness in the
processes related to determining clearance eligibility, but does not
make that task a requirement. In February 2008, one key factor we
identified in reforming the security clearance process is the use of
metrics beyond those measuring timeliness. We noted that by including
additional metrics, the joint reform team could provide a more complete
picture of the performance of a reformed clearance process. In our
November 2005 testimony, we stated that a previous government plan to
improve the clearance process placed an emphasis on monitoring the
timeliness of clearances governmentwide, but that plan detailed few of
the other elements that a comprehensive strategic plan might contain.
[Footnote 21] A similar emphasis on timeliness appears to be emerging
in the joint reform team plan. In the letter accompanying the plan,
OMB‘s Deputy Director for Management notes that the reforms proposed
are projected to enable the government to complete initial security
clearance decisions in 60 days, as called for by IRTPA.
We have previously recommended a number of additional metrics the
government could use to evaluate clearance processes and procedures.
[Footnote 22] As the joint reform team continues to develop its reform
plans and the Performance Accountability Council establishes its
progress metrics, they should consider including metrics beyond
timelines measures to aid regular congressional monitoring of clearance
process reform. Prior GAO reports as well as inspector general reports
identify a wide variety of methods and metrics that program evaluators
have used to examine clearance processes and programs. For example, our
1999 report [Footnote 23] on security clearance investigations used
multiple methods to examine numerous issues that included:
* documentation missing from investigative reports;
* investigator training (courses, course content, and number of
trainees);
* investigators‘ perceptions about the process;
* customer perceptions about the investigations; and;
* internal controls to protect against fraud, waste, abuse, and
mismanagement.
We believe that including these and other types of metrics in regular
monitoring of clearance processes could add value in current and future
reform efforts as well as supply better information for greater
congressional oversight.
Reform Efforts Contain No Funding Requirements Information:
Neither the joint reform team plan nor the executive order contains
information about funding requirements, which limits their utility as
tools for decision makers. The executive order does not require the
Performance Accountability Council or the Suitability and Security
Executive Agents to estimate the costs of reforming the security
clearance system across the military, executive branch, and
intelligence community. In February 2008, we noted that the joint
reform team should provide the long-term funding requirements to
implement changes to the security clearance process. However, this
information was not included in the plan or the executive order. In the
letter accompanying the plan, OMB‘s Deputy Director for Management
notes that updates will be provided to the President in the coming
months as additional reforms are validated, cost-benefit analysis is
completed, and funding made available.
We believe that not including the long-term funding requirements limits
the utility of the joint reform team‘s plan as a tool for decision
makers in both the executive and legislative branches to carry out
their budgetary development and oversight functions. We noted in our
February 2008 statement to this committee that without more information
on funding requirements for the joint reform team‘s proposed process,
the executive branch is limited in its ability to compare and
prioritize this proposal for reforming the clearance processes against
other pressing needs. In addition, as the joint reform team consults
with Congress on its security clearance reform plans, the absence of
any funding requirements to implement these reforms limits Congress‘s
ability to fully assess appropriation requests.
As we have previously testified, incorporating these four factors will
be key to reforming the security clearance process. These factors may
be addressed in the implementation plan that OMB says it will issue in
December 2008.
Implementation of Reform Efforts Could Also Benefit from Incorporating
Additional Best Practices GAO Identified for Successful Transformation:
Moving forward, as reform efforts transition into the implementation
phase during the remaining months of this calendar year, the joint
reform team, the Performance Accountability Council and all other
agencies involved in reform implementation efforts could benefit from
incorporating additional best practices for agencies to successfully
transform their cultures. This is particularly important since a
central theme of the 9/11 Commission Report [Footnote 24] was that one
of the major challenges facing the intelligence community is moving
from a culture of ’need to know“ to a culture of ’need to share.“ These
additional best practices include, among other things (1) establishing
a coherent mission and integrating strategic goals to guide the
transformation, (2) focusing on a key set of principles and priorities
at the outset of the transformation, (3) setting implementation goals
and a timeline to build momentum and show progress from day one, and
(4) establishing a communication strategy to create shared expectations
and report related progress. Table 1 provides more detail about these
selected additional key practices and their associated implementation
steps.
Table 1: Selected Additional Key Practices and Implementation Steps for
Mergers and Transformations:
Practice: Establish a coherent mission and integrated strategic goals to
guide the transformation;
Implementation Steps:
* Adopt leading practices for results-oriented strategic planning and
reporting.
Practice: Focus on a key set of principles and priorities at the outset
of the transformation;
Implementation Steps:
* Embed core values in every aspect of the organization to reinforce
the new culture.
Practice: Set implementation goals and a timeline to build momentum and
show progress from day one;
Implementation Steps:
* Make public implementation goals and timeline;
* Seek and monitor employee attitudes and take appropriate follow-up
actions;
* Identify cultural features of merging organizations to increase
understanding of former work environments;
* Attract and retain key talent;
* Establish an organizationwide knowledge and skills inventory to
exchange knowledge among merging organizations.
Practice: Establish a communication strategy to create shared
expectations and report related progress;
Implementation Steps:
* Communicate early and often to build trust;
* Ensure consistency of message;
* Encourage two-way communication;
* Provide information to meet specific needs of employees.
Source: GAO-03-669.
[End of table]
Further, IRTPA sets clearance processing timeliness requirements,
general specifications for an integrated database, and reciprocity
across the government. Using the best practices to meet IRTPA
requirements can assist the Performance Accountability Council in the
development of a coherent mission, guide the transformation, and focus
efforts on key principles and priorities. For example, timeliness is an
important strategic goal not only because IRTPA establishes phased
milestones for reducing the time to complete clearances, but also
because the reform efforts are intended to improve clearance processing
times. In the first period, from December 2006 to December 2009, the
act requires agencies to make a determination of eligibility for a
clearance on at least 80 percent of all personnel security clearance
applications within 120 days after the date that the application is
received by an authorized investigative agency, with a maximum of 90
days allotted for the investigation phase and a maximum of 30 days
allotted for the adjudication phase. After December 17, 2009, the act
requires agencies to make a clearance determination on at least 90
percent of all applications within 60 days of the application receipt
date, allowing no more than 40 days for the investigation and 20 days
for the adjudication. To OMB‘s credit, it has placed great emphasis on
meeting IRTPA‘s requirements since 2004 and clearance processing times
are improving; however, an OMB official said that the December 2009
timeliness goal will be difficult to achieve. As the clearance
determination process reform is implemented, one of the key
transformation steps is to keep the implementation goals and timeline
public, so that those exercising oversight can monitor the achievement
and achievability of IRTPA timeliness requirements. The linkage of
steps and timelines to long-term IRTPA requirements may help establish
a coherent mission to guide the transformation.
In addition, focusing on a key set of principles and priorities at the
outset of the transformation can help the joint reform team ensure that
the core values of the plan are reinforced as the plan is implemented.
For example, IRTPA requires the directors of OPM and OMB to establish
an integrated and secure database system for security clearance data
from all entities conducting investigations and adjudications across the
federal government. The joint reform team is currently conducting
demonstration projects across the federal government to determine which
existing information technology system, or integrated set of systems,
can best support the clearance process across the federal government.
As these options are explored, it is important to identify the culture
and operating environment of each agency that will use the data system
to increase the joint reform team‘s understanding of each agency‘s
needs. Establishing this integrated database is a complex process that
would benefit from a timeline with milestones to build momentum and
show progress toward the implementation of the integrated database
across multiple agencies. IRTPA also requires reciprocity of clearances
across federal agencies, meaning that all comparable security clearance
background investigations and determinations completed by an authorized
investigation and adjudication agency should be accepted by all
government agencies. Reciprocity would ease the transition of employees
from one agency to another without having to undergo multiple clearance
investigations and adjudications for similar clearances. We have
previously reported that lack of reciprocity can lead to increased
costs and workload. To demonstrate the importance for reciprocity
governmentwide, it would be helpful for those leading the reform to
articulate the compelling reason for accepting other federal agencies‘
clearances while continuing the granting of security clearances.
Furthermore, setting implementation goals and timelines to meet those
goals up front, and also making them public, can enable those involved
in reform efforts to demonstrate progress”from day one”in any
transformation effort, and also enable them to identify steps still to
be accomplished. Cultural transformation can take years, and having
established implementation goals and timelines will be key to
maintaining momentum for the reform efforts when the administration
changes in January 2009. The process of establishing goals and
timelines can also serve to help identify the cultures of all entities
involved in the reform and, in so doing, increase understanding of the
reform and bring clarity to the interim steps and milestones that need
to be accomplished in order to achieve success.
Finally, during all phases of the reform process, it will be important
for the joint reform team and the Performance Accountability Council to
establish a solid communication strategy to create shared expectations
and report progress, and to establish this communication strategy early
in the process. Given that these reform efforts involve a number of
agencies across the federal government, a solid communication strategy
can promote momentum, build trust among affected agencies, and ensure
consistency of message across agencies. Officials from OMB told us that
the key elements of the best practices we identified are currently a
part of the reform efforts, adding that the joint reform team and
Performance Accountability Council are following these best practices
as they develop their implementation plan. Any opportunity to make the
use of these practices transparent could serve to sustain progress in
the reform efforts, not only over the next few months, but also in the
coming years.
We believe that incorporating these best practices is key to the
implementation of personnel security reform and will also help inform
the implementation plan that will be issued before the upcoming change
in administrations. OMB informed us in July 2008 that the Performance
Accountability Council plans to issue another report in December 2008
that will provide details about the desired reformed process to be
implemented, a general implementation and adoption schedule, the fiscal
and related cost/benefit relationship issues, and an estimate of the
likely timeliness and quality that will result from the reformed
automated system. This report would benefit from incorporating these
best practices and statutory requirements to the extent possible.
Concluding Observations:
Our preliminary observations of the current reform efforts”the joint
reform team‘s plan to develop a new governmentwide end-to-end security
clearance process and Executive Order 13467 that establishes a
leadership structure”are that they represent positive steps to address
past impediments and manage security clearance reform efforts. The
joint reform team plan includes the input of key stakeholders,
addresses clearance need validation, and has begun to address some
aspects of building quality into the clearance system. As the
implementation of the security clearance reform efforts proceeds, we
believe that the key factors we have previously identified for
reforming the personnel security clearance process, key practices we
have identified for guiding transformation, and IRPTA requirements
could further inform and improve the process. Nonetheless, much remains
to be done before a new system can be fully implemented. We look
forward to conducting a more detailed review of these reform efforts as
requested by the Chairman of the Permanent Select Committee on
Intelligence of the U.S. House of Representatives and you in your
capacity as chairwoman of this Subcommittee. In that review, we plan to
more fully examine the issues presented in this statement and others
as the efforts move forward.
Madam Chairman and Members of the Subcommittee, this concludes my
prepared statement. I would be happy to answer any questions you may
have at this time.
Contact and Acknowledgments:
For further information regarding this testimony, please contact me at
(202) 512-3604 or farrellb@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this statement. Individuals who made key contributions to this
testimony are David E. Moser, Assistant Director; Renee S. Brown, Sara
G. Cradic, James P. Klein, Ron La Due Lake, and Gregory Marchand.
[End of section]
Highlights of previous reports:
Personnel Clearances:
Key Factors for Reforming the Security Clearance Process:
Statement of Brenda S. Farrell:
Defense Capabilities and Management:
GAO-08-776T:
GAO Highlights:
Highlights of GAO-08-776T, a testimony 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.
Why GAO Did This Study:
Since 1974, GAO has examined personnel security clearance processes and
acquired a historical view of key factors to consider in reform
efforts. GAO placed the Department of Defense‘s (DOD) personnel
security clearance program, which represents 80 percent of federal
government clearances, on its high-risk list in 2005 due to long-
standing problems. These problems include incomplete investigative
reports from the Office of Personnel Management (OPM), the agency
primarily responsible for providing clearance investigation services;
the granting of some clearances by DOD adjudicators even when required
data were missing from the investigative reports used to make such
determinations; and delays in completing clearance processing. Delays
can lead to a heightened risk of disclosure of classified information,
additional costs and delays in completing related contracts, and
problems retaining qualified personnel. DOD has reported on these
continuing delays. However, there has been recent high-level
governmentwide attention to improving the process, including
establishing a team to develop a reformed federal government security
clearance process.
This statement addresses four key factors that should be considered in
personnel security clearance reforms. This statement draws on GAO‘s
past work, which included reviews of clearance-related documents and
interviews of senior officials at DOD and OPM.
What GAO Found:
Efforts to reform personnel security clearance processes should
consider, among other things, the following four key factors: (1) a
strong requirements-determination process, (2) quality in all clearance
processes, (3) metrics to provide a fuller picture of clearance
processes, and (4) long-term funding requirements of security clearance
reform. In February 2008, GAO noted that a sound requirements process
is important because requesting a clearance for a position in which it
will not be needed, or in which a lower-level clearance would be
sufficient, will increase both costs and investigative workload
unnecessarily. For example, the cost of obtaining and maintaining a top
secret clearance for 10 years is approximately 30 times greater than
the cost of obtaining and maintaining a secret clearance for the same
period. Also, changing a position‘s clearance level from secret to top
secret increases the investigative workload for that position about 20-
fold.
Building quality throughout the clearance process could promote
positive outcomes, including more reciprocity governmentwide. However,
agencies have paid little attention to this factor despite GAO‘s 2006
recommendation to place more emphasis on quality. For example, the
Office of Management and Budget‘s (OMB) February 2007 report on
security clearances documented quality with a single metric in only one
of the six phases of the process. Further, OMB did not discuss the
development or existence of any metric measuring the level of quality
in security clearance processes or products in its February 2008
report. Concerns about the quality of investigative and adjudicative
work underlie the continued reluctance of agencies to accept clearances
issued by other agencies; thus, government resources may be used to
conduct duplicative investigations and adjudications.
Federal agencies‘ efforts to monitor clearance processes emphasize
timeliness, but additional metrics should be developed to provide a
fuller picture of the performance of the clearance process. GAO has
highlighted a variety of metrics in its reports (e.g., completeness of
investigative reports, staff‘s and customers‘ perceptions of the
process, and the adequacy of internal controls), all of which could add
value in monitoring clearance processes. The emphasis on timeliness is
due in part to the Intelligence Reform and Terrorism Prevention Act of
2004 which provides guidelines for the speed of completing clearances
and requires annual reporting of that information to Congress.
Providing Congress with the long-term funding requirements to implement
changes to security clearance processes could enable more-informed
congressional oversight. Reform efforts should identify long-term
funding requirements to implement proposed changes, so that decision
makers can compare and prioritize alternate reform proposals in times
of fiscal constraints. The absence of long-term funding requirements to
implement reforms would limit decision makers‘”in the executive and
legislative branches”ability to carry out their budgetary development
and oversight functions.
To view the full product, click on [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-776T]. For more information,
contact Brenda S. Farrell at (202) 512-3604 or farrellb@gao.gov.
[End of highlight]
DOD Personnel Clearances:
DOD Faces Multiple Challenges in Its Efforts to Improve Clearance
Processes for Industry Personnel:
Statement of Jack E. Edwards, Acting Director:
Defense Capabilities and Management:
GAO-08-470T:
GAO Highlights:
Highlights of GAO-08-470T, a testimony before the Subcommittee on
Readiness, Committee on Armed Services, House of Representatives.
Why GAO Did This Study:
The Department of Defense (DOD) maintains approximately 2.5 million
security clearances on servicemembers, federal DOD civilian employees,
industry personnel for DOD and 23 other federal agencies, and employees
in the legislative branch. Delays in determining eligibility for a
clearance can heighten the risk that classified information will be
disclosed to unauthorized sources, increase contract costs, and pose
problems in attracting and retaining qualified personnel. In this
statement, GAO addresses: (1) the status of DOD‘s efforts to improve
its projections of the numbers of clearances needed for industry
personnel, and (2) other long-standing challenges that have a negative
effect on the efficiency and effectiveness of DOD‘s personnel security
clearance program for industry personnel. This statement is based on a
report GAO is issuing today (GAO-08-350) and other prior work, which
included reviews of clearance-related documents and interviews of
senior officials at DOD and the Office of Personnel Management (OPM).
What GAO Found:
DOD has had a long-standing challenge in accurately projecting the
number of clearance investigations that will be required in the future
for industry personnel. The Office of Management and Budget (OMB)
developed criteria for these projections in November 2005. It
established a governmentwide goal for agencies to refine their
projections of the number of clearance investigations that will be
required in any given year to be within 5 percent of the number of
actual requests for investigation. At a May 2006 congressional hearing,
an OPM Assistant Director stated that DOD had exceeded its
departmentwide projection by 59 percent for the first half of fiscal
year 2006. The negative effects of such inaccurate projections include
impediments to workload planning and funding. GAO noted the problem
with the accuracy of DOD‘s projections in its February 2004 report and
recommended that DOD improve its projections for industry personnel. In
the report it is issuing today, GAO noted that DOD has initiated
changes to improve its estimates of future investigation needs and is
conducting research that may change these methods further. For example,
in 2006, DOD took steps to increase the response rate of its annual
survey used as a basis for determining its projections. In 2007, it
changed its methods for analyzing data that informs its projections.
However, DOD has not yet demonstrated the effectiveness of these
changes.
DOD must address additional long-standing challenges or issues in order
to improve the efficiency and accuracy of its personnel security
clearance program for industry personnel. First, continuing delays in
determining clearance eligibility can result in increased costs and
risk to national security. For example, when new employees‘ clearances
are delayed, it affects their abilities to perform their duties fully
since they do not have access to classified material. Second, DOD and
the rest of the federal government provide limited information to one
another on how they individually ensure the quality of clearance
products and procedures, which affects reciprocity of clearances.
Reciprocity occurs when one government agency fully accepts a security
clearance granted by another government agency. GAO‘s September 2006
report noted that agencies may not reciprocally recognize clearances
granted by other agencies because of concerns that other agencies may
have granted clearances based on inadequate investigations and
adjudications. Third, in DOD‘s August 2007 report to Congress, it
provided less than 2 years of funding-requirements information, which
limits congressional awareness of future year requirements for this
program. Fourth, DOD does not have a comprehensive DOD-specific plan to
address delays in its clearance program. While there is a
governmentwide effort to reform the clearance process, it is projected
not to be operational until beyond December 2008.
What GAO Recommends:
GAO made recommendations to address DOD‘s security clearance
challenges. For example, in the report we are issuing today, GAO
recommended that DOD provide Congress with information on funding and
quality in clearance processes. DOD concurred and indicated it would
provide that information in its 2009 report to Congress.
To view the full product, click on [hyperlink, http://www.GAO-08-470T].
For more information, contact Jack Edwards at (202) 512-8246 or
edwardsj@gao.gov, or Brenda Farrell at (202) 512-3604 or
farrellb@gao.gov.
[End of highlight]
Personnel Clearances:
Key Factors to Consider in Efforts to Reform Security Clearance
Processes:
Statement of Brenda S. Farrell:
Director, Defense Capabilities and Management:
GAO-08-352T:
GAO Highlights:
Highlights of GAO-08-352T, a testimony before the Subcommittee on
Intelligence Community Management, Permanent Select Committee on
Intelligence, House of Representatives.
Why GAO Did This Study:
In 2004, Congress passed the Intelligence Reform and Terrorism
Prevention Act to reform security clearance processes. Much of GAO‘s
experience in evaluating personnel security clearance processes over
the decades has consisted of examining the Department of Defense‘s
(DOD) program, which maintains about 2.5 million clearances on
servicemembers, DOD civilian employees, legislative branch employees,
and industry personnel working for DOD and 23 other federal agencies.
Long-standing delays in processing applications”and other problems in
DOD‘s clearance program”led GAO to designate it a high-risk area in
2005. GAO also has documented clearance-related problems in other
agencies.
For this hearing, GAO was asked to identify key factors that could be
applied in personnel security clearance reform efforts. To identify key
factors, GAO drew upon its past reports and institutional knowledge.
For those reports, GAO reviewed laws, executive orders, policies,
reports, and other documentation related to the security clearance
process; examined samples of cases of personnel granted top secret
eligibility; compared documentation in those sampled cases against
federal standards; and interviewed a range of cognizant government
officials.
What GAO Found:
Current and future efforts to reform personnel security clearance
processes should consider, among other things, the following four key
factors: determining whether clearances are required for positions,
incorporating quality control steps throughout the clearance processes,
establishing metrics for assessing all aspects of clearance processes,
and providing Congress with the long-term funding requirements of
security clearance reform. Requesting a clearance for a position in
which it will not be needed, or in which a lower-level clearance would
be sufficient, will increase both costs and investigative workload
unnecessarily. For example, changing the clearance needed for a
position from a secret to top secret increases the investigative
workload for that position about 20-fold and uses 10 times as many
investigative staff hours.
Emphasis on quality in clearance processes could promote positive
outcomes, including more reciprocity among agencies in accepting each
others‘ clearances. Building quality throughout clearance processes is
important, but government agencies have paid little attention to
quality, despite GAO‘s repeated suggestions to place more emphasis on
quality. Even though GAO identified the government‘s primary metric for
assessing quality”the percentage of investigative reports returned for
insufficiency during the adjudicative phase”as inadequate by itself in
1999, the Office of Management and Budget and the Office of Personnel
Management continue to use that metric. Concerns about the quality of
investigative and adjudicative work underlie the continued reluctance
of agencies to accept clearances issued by other agencies; as a result,
government resources are used to conduct duplicative investigations and
adjudications.
Many efforts to monitor clearance processes emphasize measuring
timeliness, but additional metrics could provide a fuller picture of
clearance processes. The emphasis on timeliness is due in part to
recent legislation that provides specific guidelines regarding the
speed with which clearances should be completed and requires annual
reporting of that information to Congress. GAO has highlighted a
variety of metrics in its reports (e.g., completeness of investigative
and adjudicative reports, staff‘s and customers‘ perceptions of the
processes, and the adequacy of internal controls), all of which could
add value in monitoring clearance processes and provide better
information to allow improved oversight by Congress and the Executive
Branch.
Another factor to consider in reform efforts is providing Congress with
the long-term funding requirements to implement changes to security
clearance processes. DOD‘s August 2007 congressionally mandated report
on industry clearances identified its immediate funding needs but did
not include information on the funding requirements for fiscal year
2009 and beyond. The inclusion of less than 2 future years of budgeting
data in the DOD report limits Congress‘s ability to carry out its long-
term oversight and appropriations functions pertaining to industry
personnel security clearances.
To view the full product, click on [hyperlink, http://www.GAO-08-352T].
For more information, contact Brenda S. Farrell at (202) 512-3604 or
farrellb@gao.gov.
[End of highlight]
DOD Personnel Clearances:
Delays and Inadequate Documentation Found for Industry Personnel:
Statement of Derek B. Stewart, Director:
Defense Capabilities and Management:
GAO-07-842T:
GAO Highlights:
Highlights of GAO-07-842T, a testimony 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
Why GAO Did This Study:
Individuals working for the private industry are playing a larger role
in national security work conducted by Department of Defense (DOD) and
other federal agencies. As of May 2006, industry personnel held about
34 percent of DOD-maintained personnel security clearances. The damage
that the unauthorized disclosure of classified information can cause to
national security necessitates the prompt and careful consideration of
who is granted a security clearance. Long-standing delays in
determining clearance eligibility and other challenges led GAO to
designate the DOD personnel security clearance program as a high-risk
area in January 2005 and again in GAO‘s January 2007 update of the high-
risk areas. In February 2005, DOD transferred its security clearance
investigations functions to the Office of Personnel Management (OPM)
and now obtains almost all of its clearance investigations from OPM.
The Office of Management and Budget (OMB) is responsible for effective
implementation of policy relating to determinations of eligibility for
access to classified information.
This testimony addresses the timeliness of the process and completeness
of documentation used to determine eligibility of industry personnel
for top secret clearances in January and February 2006. This statement
relies primarily on GAO‘s September 2006 report (GAO-06-1070).
What GAO Found:
GAO‘s analysis of timeliness data showed that industry personnel
contracted to work for the federal government waited more than 1 year
on average to receive top secret clearances, longer than OMB- and 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 the government
plan 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 began 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 that
OMB and OPM report to Congress on the timeliness of the clearance
process do not portray the full length of time it takes many applicants
to receive a clearance. GAO found several issues with the statistics,
including limited information on reinvestigations for clearance
updating and failure to measure the total time it took to complete the
various phases of the clearance process. 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. 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. GAO 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 in the adjudicative report that the information was
missing. 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.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-842T].
To view the full product, click on the link above. For more
information, contact Derek B. Stewart on (202)512-5559 or
stewartd@gao.gov.
[End of highlight]
Highlights: High-Risk Series: Department of Defense Personnel Security
Clearance Program:
GAO Highlights:
For additional information about this high-risk area, contact Derek B.
Stewart at (202) 512-5559 or stewartd@gao.gov.
Why Area Is High Risk:
The Department of Defense (DOD) is responsible for about 2.5 million
security clearances issued to servicemembers, DOD civilians, and
industry personnel who work on contracts for DOD and 23 other federal
agencies. The clearances give workers access to information, the
unauthorized disclosure of which could, in some cases, cause
exceptionally grave damage.
Long-standing delays in determining clearance eligibility and other
challenges led GAO to designate DOD‘s personnel security clearance
program as a high-risk area in January 2005. DOD transferred its
security clearance investigations functions to the Office of Personnel
Management (OPM) in February 2005 and now obtains almost all of its
clearance investigations from OPM, which conducts about 90 percent of
all federal clearance investigations. Executive Order 13381 assigned
the Office of Management and Budget (OMB) responsibility for effective
implementation of policy relating to determinations of eligibility for
access to classified information.
What GAO Found:
Problems continue with DOD‘s clearance program even though OMB, OPM,
and DOD took positive steps to monitor some GAO-identified concerns.
For example, their November 2005 plan outlined many timeliness
measures, but included only two measures of quality, both of which were
deficient. DOD‘s consistently inaccurate projections of clearance
requests have impeded workload planning and funding. Although OMB set a
government goal of projected cases and actual requests being within 5
percent of one another, OPM reported that DOD exceeded its projected
number by 59 percent for the first half of fiscal year 2006. In
addition, GAO reviewed 50 OPM-produced investigative reports and found
documentation missing from 47. Despite the missing information, which
in most cases pertained to residences, employment, and education, DOD
adjudicators granted clearance eligibility but did not request missing
investigative information or fully document unresolved issues in 27 of
the 50 reviewed reports. Incomplete investigative or adjudicative
reports could undermine OMB‘s efforts to achieve clearance reciprocity
(an agency accepting a clearance awarded by another agency). OPM has
reported that it is using new personnel and procedures to improve the
quality of its investigative reports.
Furthermore, clearances continue to take longer than the time
prescribed in government goals. This occurred in the application-
submission, investigation, and adjudication (determining clearance
eligibility) phases of the clearance process, despite positive steps
that include additional congressional and OMB oversight, DOD‘s growing
use of OPM‘s electronic application-submission system, and OPM
obtaining more investigators. For example, GAO found that the
application-submission phase averaged 111 days for industry personnel
seeking initial top secret clearances, but the government goal is 14
days. Multiple reviews of applications and manually entering data from
paper forms are two reasons for the delays. OPM stated that paper
submissions take on average 14 days longer than electronic submissions.
For August 2006, OPM reported that 54 percent of DOD applications were
submitted using OPM‘s electronic submission system. In the
investigation phase, GAO found that it took an average of 286 days for
initial clearances”compared with the goal of 180 days”and 419 days for
clearance updates for the 2,259 industry personnel who were granted
clearance eligibility in January and February 2006. Although OPM
increased its workforce, it faces many impediments to improving
investigation timeliness, including the backlog of requests for
investigations and difficulty obtaining national, state, and local
records. The average time for adjudication was 39 days for industry
personnel, compared with a mandate that starts in December 2006
requiring that 80 percent of adjudications 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.
Delays in determining initial clearance eligibility can increase the
cost of performing classified work, and delays in updating clearances
may increase the risk of national security breaches.
What Remains to Be Done:
To improve its security clearance program, DOD needs to take actions
that include (1) improving the accuracy of its projected need for
clearances, (2) working with OMB and OPM to fully measure and report
all of the time required to determine clearance eligibility, (3)
partnering with OPM to improve the timeliness and completeness of
clearance-application submissions and investigative reports, and (4)
implementing procedures to eliminate documentation problems.
[End of highlight]
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 highlight]
DOD Personnel Clearances:
New Concerns Slow Processing of Clearances for Industry Personnel:
Statement of Derek B. Stewart:
Director:
Defense Capabilities and Management:
GAO-06-748T:
GAO Highlights:
Highlights of GAO-06-748T a testimony 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.
Why GAO Did This Study:
The Department of Defense (DOD) is responsible for about 2 million
active personnel security clearances. About one-third of the clearances
are for industry personnel working on contracts for DOD and more than
20 other executive agencies. Delays in determining eligibility for a
clearance can heighten the risk that classified information will be
disclosed to unauthorized sources and increase contract costs and
problems attracting and retaining qualified personnel. Long-standing
delays in completing hundreds of thousands of clearance requests and
numerous impediments that hinder DOD‘s ability to accurately estimate
and eliminate its clearance backlog led GAO to declare DOD‘s personnel
security clearance program a high-risk area in January 2005.
This testimony presents GAO‘s (1) preliminary observations from its
ongoing review of the timeliness and completeness of clearances, (2)
concerns about the upcoming expiration of an executive order that has
resulted in high level commitment to improving the governmentwide
clearance process, and (3) views on factors underlying DOD‘s decision
to stop accepting clearance requests for industry personnel.
What GAO Found:
GAO‘s ongoing review of the timeliness and completeness of security
clearance processes for industry personnel has provided three
preliminary observations. First, communication problems between DOD and
the Office of Personnel Management (OPM) may be limiting governmentwide
efforts to improve the personnel security clearance process. Second,
OPM faces performance problems due to the inexperience of its domestic
investigative workforce, and it is still in the process of developing a
foreign presence to investigate leads overseas. Third, some DOD
adjudication facilities have stopped accepting closed pending
cases”that is, investigations formerly forwarded to DOD adjudicators
from OPM”even though some required investigative information was not
included.
In addition, the expiration of Executive Order 13381 could slow
improvements in the security clearance processes governmentwide, as
well as for DOD in particular. The executive order, which among other
things delegated responsibility for improving the clearance process to
the Office of Management and Budget (OMB), is set to expire on July 1,
2006. GAO has been encouraged by the high level of commitment that OMB
has demonstrated in the development of a plan to address clearance-
related problems. Because there has been no indication that the
executive order will be extended, GAO is concerned about whether the
progress that has resulted from OMB‘s high-level management involvement
will continue. Issues such as OPM‘s need to establish an overseas
presence are discussed as potential reasons why OPM may not be in a
position to assume an additional high-level commitment if OMB does not
continue in its current role.
Finally, inaccurate projections of clearance requests and funding
constraints are delaying the processing of security clearance requests
for industry personnel. DOD stopped processing new applications for
clearance investigations for industry personnel on April 28, 2006. DOD
attributed its actions, in part, to an overwhelming volume of requests
for industry personnel security investigations. DOD‘s long-standing
inability to accurately project its security clearance workload makes
it difficult to determine clearance-related budgets and staffing
requirements. The funding constraints that also underlie the stoppage
are related to the transfer of DOD‘s personnel security investigations
functions to OPM. DOD has questioned some of the costs being charged by
OPM and has asked OMB to mediate the DOD-OPM dispute. Information from
the two agencies indicates that OMB has directed the agencies to
continue to work together to resolve the matter. According to officials
in the DOD and OPM inspector general offices, they are investigating
the billing dispute and expect to report on the results of their
investigations this summer.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-748T].
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 highlight]
DOD Personnel Clearances:
Government Plan Addresses Some Long-standing Problems with DOD's
Program, But Concerns Remain:
Statement of Derek B. Stewart, Director:
Defense Capabilities and Management:
GAO-06-233T:
GAO Highlights:
Highlights of GAO-06-233T, a testimony 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:
Why GAO Did This Study:
Unauthorized disclosure of classified information can cause up to
exceptionally grave damage to national security. The Department of
Defense (DOD) is responsible for about 2 million personnel with
clearances that allow them access to classified information. While most
of these clearances are for servicemembers and DOD‘s employees and
contractors, DOD is also responsible for contractors‘ clearances for
more than 20 other agencies, as well as for congressional staff. Due to
long-standing problems with DOD‘s clearance program, GAO designated it
a high-risk area in January 2005. In February 2005, when DOD
transferred its personnel security investigative functions to the
Office of Personnel Management (OPM), the average wait for a top secret
clearance governmentwide was over 1 year. In June 2005, Executive Order
13381 gave the Office of Management and Budget (OMB) authority to
retain or assign to any executive agency any process relating to
determinations of eligibility for access to classified information. OPM
is assisting OMB with the development of the plan.
GAO was asked to assess the government plan. This testimony will
provide GAO‘s preliminary review of how well the government plan (1)
adheres to the standards of comprehensive strategic planning and (2)
addresses the timeliness and quality of the security clearance process.
Finally, GAO will discuss the actions required to remove DOD‘s program
from GAO‘s high-risk list.
What GAO Found:
We are encouraged by the level of commitment demonstrated by OMB in
overseeing the preparation of the government plan for addressing
problems in the personnel security clearance process. The plan
represents an important step toward addressing some long-standing
concerns GAO has raised in this area. It includes some elements that a
comprehensive strategic plan should contain, such as metrics that will
be used to monitor the timeliness of the security clearance process
governmentwide. However, the plan provides few details on other
features that GAO looks for in a comprehensive strategic plan. For
example, in some cases, the plan does not provide details on discrete
actions the government would take or their projected completion dates.
In addition, the plan does not always include details on the resources
required to accomplish the plan‘s objectives. Finally, the plan does
not describe potential risks or mitigation plans to address potential
risks.
Although the government plan establishes metrics to address the
timeliness of the security clearance process, they focus on some phases
of the process more than others. Specifically, the plan identifies a
wide variety of metrics for monitoring the timeliness of security
clearance investigations, but it does little to address timeliness in
the adjudication phase of the process. The government plan also
provides quarterly goals for different types of investigations.
However, the plan does not identify baseline measures or interim goals
for average adjudication processing time.
Although it explicitly acknowledges that agencies have concerns about
the quality of investigations and adjudications, the government plan
devotes little attention to monitoring and improving the quality of the
personnel security clearance process. The plan‘s primary metric for
measuring the quality of investigations”the percentage of
investigations returned by requesting agencies due to incomplete case
files”is not, by itself, a valid indicator of the quality of
investigative work. Other or additional statistics, such as the number
of counterintelligence leads generated from security clearance
investigations, may be needed. The government plan did not identify a
metric for assessing the quality of adjudications, although GAO and
other agencies have identified actions that would facilitate monitoring
and improvement of the quality of this portion of the personnel
security clearance process.
DOD must correct previously identified problems before its personnel
security clearance program can be removed from the high-risk list.
Before removing DOD‘s personnel security clearance program from the
high-risk list, GAO will examine whether OMB, OPM, and DOD have
satisfied certain criteria, including the establishment of leadership
support, sufficient resources to resolve the risk, and a corrective
action plan. GAO‘s criteria also include the presence of a program to
monitor and independently validate the effectiveness and sustainability
of any corrective actions and the agency‘s ability to demonstrate the
implementation of corrective measures.
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-233T].
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 highlight]
DOD Personnel Clearances:
Some Progress Has Been Made but Hurdles Remain to Overcome the
Challenges That Led to GAO's High-Risk Designation:
Statement of Derek B. Stewart, Director, Defense Capabilities and
Management:
GAO-05-842T:
GAO Highlights:
Highlights of GAO-05-842T, a testimony 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:
Why GAO Did This Study:
Threats to national security--such as the September 11, 2001, terrorist
attacks and high-profile espionage cases--underscore the need for
timely, high-quality determinations of who is eligible for a personnel
security clearance which allows an individual to access classified
information.
The Department of Defense (DOD) needs an effective and efficient
clearance program because it is responsible for about 2 million active
clearances and provides clearances to more than 20 other executive
agencies as well as the legislative branch. Despite these imperatives,
DOD has for more than a decade experienced delays in completing
hundreds of thousands of clearance requests and impediments to
accurately estimating and eliminating its clearance backlog. In January
2005, GAO designated DOD's personnel security clearance program as a
high-risk area. In February 2005, DOD transferred its personnel
security investigative functions and about 1,800 positions to the
Office of Personnel Management (OPM), after 2 years of negotiation
between the agencies.
This testimony provides an update on the challenges that led to GAO's
high-risk designation. It identifies both the positive steps that have
been taken to address previously identified challenges and some of the
remaining hurdles. GAO will continue to monitor this area.
What GAO Found:
While DOD has taken steps to address the problems that led to
designating its clearance program as high risk, continuing challenges
are found in each of the three stages of DOD's personnel security
clearance process. Figure 1 describes the process.
Figure 1: DOD's Process for Determining Clearance Eligibility:
[See PDF for image]
Preinvestigation stage:
After determining that a position requires the employee to have access
to classified information, the requesting organization submits an
individual's personnel security questionnaire to OPM.
Investigation stage:
OPM or one of its contractors conducts a background investigation and
forwards a report to one of DOD's adjudication facilities.
Adjudication stage:
Based on information in the investigative report, an adjudicator
determines eligibility for access to classified information, and
forwards this determination to the requesting organization.
Source: DOD.
[End of figure]
Preinvestigation: To address previously identified problems in
projecting clearance workload, DOD is identifying the military and
civilian positions that require clearances. Identifying clearance
requirements for contractor personnel is still in the planning phase.
Another problem is the efficient submission of investigation requests.
In the 2 years since DOD and OPM announced the transfer of DOD's
investigative functions and personnel to OPM, the two agencies did not
ensure the seamless submission of DOD requests to OPM. DOD is
developing software to remedy this problem.
Investigation: Delays in completing investigations are continuing. For
February 2005, OPM--which now supplies an estimated 90 percent of the
government's clearance investigations--reported that over 185,000 of
its clearance investigations had exceeded timeliness goals. OPM's
effort to add investigative staff is a positive step, but adding
thousands of staff could result in continued timeliness problems and
quality concerns as the staff gain experience. OPM's workload should
decrease because of two recent initiatives: (1) eliminating a few of
the investigative requirements for some reinvestigations of personnel
updating their clearances and (2) requiring the acceptance of
clearances and access granted to personnel moving from one agency to
another.
Adjudication: In the past, DOD had difficulty monitoring who had been
adjudicated for clearances and when the clearances needed to be
renewed. While the Joint Personnel Adjudication System has combined
databases from DOD's 10 adjudicative facilities to enhance monitoring,
wider consolidation of government databases may be required. The
Director of OPM will need to integrate all federal agencies into a
single governmentwide database in order to meet a requirement
established in a recent law. As of September 30, 2003, DOD had a
backlog of roughly 90,000 adjudications.
What GAO Recommends:
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-842T].
To view the full product, click on the link above. For more
information, contact Derek B. Stewart at (202) 512-5559 or
stewartd@gao.gov.
[End of highlight]
Intelligence Reform:
Human Capital Considerations Critical to 9/11 Commission's Proposed
Reforms:
J. Christoper Mihm, Managing Director:
Strategic Issues:
GAO Highlights:
Highlights of GAO-04-1084T, a testimony to Subcommittee on Oversight of
Government Management, the Federal Workforce, and the District of
Columbia, Committee on Governmental Affairs
Why GAO Did This Study:
GAO has performed extensive work and gained experience on government
transformation and the critical role that human capital management can
play in driving this change. Valuable lessons from these efforts could
help guide the proposed reforms in the intelligence community
envisioned by the 9/11 Commission.
At the request of this subcommittee, this statement focuses on (1) the
lessons GAO has learned from successful mergers and organizational
transformations; particularly the need for committed and sustained
leadership and the role of performance management systems in these
changes; (2) human capital flexibilities that can be used as essential
tools to help achieve these reforms; (3) how the Federal Bureau of
Investigation (FBI) is using these lessons and human capital
flexibilities to transform to meet its evolving mission in the post
9/11 environment, and (4) GAO‘s findings to date on the factors that
must be considered in the approach to the government‘s security
clearance process, as a means to accelerate the process for national
security appointments.
What GAO Found:
Recognizing that people are the critical element in transformation
initiatives is key to a successful transformation of the intelligence
community and related homeland security organizations. GAO‘s work in
successful mergers and transformations shows that incorporating
strategic human capital management approaches will help sustain any
reforms in the intelligence community. Successful major change
management initiatives in large public and private sector organizations
can often take at least 5 to 7 years to create the accountability
needed to ensure this success. As a result, committed and sustained
leadership is indispensable to making lasting changes in the
intelligence community. Accordingly, the Congress may want to consider
lengthening the terms served by the directors of the intelligence
agencies, similar to the FBI Director‘s 10-year term. One of the major
challenges facing the intelligence community is moving from a culture
of a ’need to know“ to a ’need to share“ intelligence information. The
experience of leading organizations suggests that performance
management systems”that define, align, and integrate institutional,
unit, and individual performance with organizational outcomes”can
provide incentives and accountability for sharing information to help
facilitate this shift.
Significant changes have been underway in the last 3 years regarding
how the federal workforce is managed. The Congress passed legislation
providing certain governmentwide human capital flexibilities, such as
direct hire authority. While many federal agencies have received human
capital flexibilities, others may be both needed and appropriate for
intelligence agencies, such as providing these agencies with the
authority to hire a limited number of term-appointed positions on a
noncompetitive basis.
Human capital challenges are especially significant for the
intelligence organizations, such as the FBI, that are undergoing a
fundamental transformation in the aftermath of September 11, 2001. For
the last 3 years, we have been using the lessons learned from
successful transformations to monitor the FBI‘s progress as it
transforms itself from its traditional crime enforcement mission to
its post 9/11 homeland security priorities”counterterrorism,
counterintelligence and cyber crimes. For example, the FBI has
undertaken a variety of human capital related initiatives, including
major changes in realigning, retraining, and hiring special agents and
analysts with critical skills to address its top priorities.
The 9/11 Commission recommended that a single federal security
clearance agency should be created to accelerate the government‘s
security clearance process. Several factors must be considered in
determining the approach to this process. The large number of requests
for security clearances for service members, government employees, and
others taxes a process that already is experiencing backlogs and
delays. Existing impediments”such as the lack of a governmentwide
database of clearance information, a large clearance workload, and too
few investigators”hinder efforts to provide timely, high-quality
clearance determinations.
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-1084T].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact J. Christopher Mihm
(202) 512-6806 or mihmj@gao.gov.
[End of highlight]
[End of section]
Related GAO Products:
Personnel Clearances: Key Factors for Reforming the Security Clearance
Process. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-776T].
Washington, D.C.: May 22, 2008.
Employee Security: Implementation of Identification Cards and DOD's
Personnel Security Clearance Program Need Improvement. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-551T]. Washington, D.C.: April
9, 2008.
DOD Personnel Clearances: Questions for the Record Related to the
Quality and Timeliness of Clearances. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-580R]. Washington, D.C.: March
25. 2008.
Intelligence Reform: GAO Can Assist the Congress and the Intelligence
Community on Management Reform Initiatives. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-413T]. Washington, D.C.:
February 29, 2008.
Personnel Clearances: Key Factors to Consider in Efforts to Reform
Security Clearance Processes. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-352T]. Washington, D.C.: February 27, 2008.
DOD Personnel Clearances: Improved Annual Reporting Would Enable More
Informed Congressional Oversight. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-350]. Washington, D.C.: February 13, 2008.
Homeland Security: Federal Efforts Are Helping to Alleviate Some
Challenges Encountered by State and Local Information Fusion Centers.
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-350]. Washington,
D.C.: October 30, 2007.
Defense Business Transformation: A Full-time Chief Management Officer
with a Term Appointment Is Needed at DOD to Maintain Continuity of
Effort and Achieve Sustainable Success. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-132T]. Washington, D.C.:
October 16, 2007.
DOD Personnel Clearances: Delays and Inadequate Documentation Found For
Industry Personnel. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-
07-842T]. Washington, D.C.: May 17, 2007.
Maritime Security: Observations on Selected Aspects of the SAFE Port
Act. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-754T].
Washington, D.C.: April 26, 2007.
High-Risk Series: An Update, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-310]. Washington, D.C.: January 2007.
DOD Personnel Clearances: Additional OMB Actions Are Needed To Improve
The Security Clearance Process, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-1070]. Washington, D.C.: September 2006.
Managing Sensitive Information: DOD Can More Effectively Reduce the
Risk of Classification Errors, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-706]. Washington, D.C.: June 30, 2006.
DOD Personnel Clearances: Questions and Answers for the Record
Following the Second in a Series of Hearings on Fixing the Security
Clearance Process. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-
693R]. Washington, D.C.: June 14, 2006.
DOD Personnel Clearances: New Concerns Slow Processing of Clearances
for Industry Personnel. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-748T]. Washington, D.C.: May 17, 2006.
DOD Personnel Clearances: Funding Challenges and Other Impediments Slow
Clearances for Industry Personnel. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-747T]. Washington, D.C.: May 17, 2006.
Questions for the Record Related to DOD‘s Personnel Security Clearance
Program and the Government Plan for Improving the Clearance Process.
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?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. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-06-233T]. Washington, D.C.:
November 9, 2005.
Defense Management: Better Review Needed of Program Protection Issues
Associated with Manufacturing Presidential Helicopters. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-06-71SU]. Washington, D.C.:
November 4, 2005.
Questions for the Record Related to DOD‘s Personnel Security Clearance
Program. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-988R].
Washington, D.C.: August 19, 2005.
Industrial Security: DOD Cannot Ensure Its Oversight of Contractors
under Foreign Influence Is Sufficient. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?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. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-
842T]. Washington, D.C.: June 28, 2005.
DOD‘s High-Risk Areas: Successful Business Transformation Requires
Sound Strategic Planning and Sustained Leadership. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-05-520T]. Washington, D.C.: April
13, 2005.
High-Risk Series: An Update. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-05-207]. Washington, D.C.: January 2005.
Intelligence Reform: Human Capital Considerations Critical to 9/11
Commission‘s Proposed Reforms. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?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. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?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. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-202T].
Washington, D.C.: May 6, 2004.
Industrial Security: DOD Cannot Provide Adequate Assurances That Its
Oversight Ensures the Protection of Classified Information. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-04-332]. Washington, D.C.: March
3, 2004.
DOD Personnel Clearances: DOD Needs to Overcome Impediments to
Eliminating Backlog and Determining Its Size. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-04-344]. Washington, D.C.:
February 9, 2004.
Results-Oriented Cultures: Implementation Steps to Assist Mergers and
Organizational Transformations. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-03-669]. Washington, D.C.: July 2, 2003.
[End of section]
Footnotes:
[1] See Highlights pages from select GAO products and list of related
GAO Products at the end of this statement.
[2] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-05-207] (Washington, D.C.:
January 2005).
[3] GAO, Personnel Clearances: Key Factors to Consider in Efforts to
Reform Security Clearance Processes, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-352T] (Washington, D.C.: Feb. 27, 2008).
[4] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-07-310] (Washington, D.C.:
January 2007).
[5] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-352T].
[6] Pub. L. No. 108-458 § 3001 (2004).
[7] GAO, Results Oriented Cultures: Implementation Steps to Assist
Mergers and Organizational Transformations, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-03-669]. (Washington, D.C.: July
2, 2003).
[8] 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), as amended.
[9] 5 C.F.R. § 1312.4 (2007).
[10] Executive Order 13381 was revoked on June 30, 2008, by Executive
Order 13467, which established OMB‘s Deputy Director for Management as
the Chair of the Performance Accountability Council.
[11] Since June 2007, the goal of the joint reform team expanded to
include the elimination of duplicative steps in the investigations for
security clearances and suitability determinations for federal
employment. In addition, OPM is also now a member of the joint reform
team.
[12] GAO, DOD Personnel Clearances: Improved Annual Reporting Would
Enable More Informed Congressional Oversight. [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-350]. (Washington, D.C.: Feb.
13, 2008).
[13] The Suitability Executive Agent is responsible for developing
consistent policies and timely investigations and adjudications
relating to determinations of suitability, of whether a person is
suitable or is not suitable for employment in covered positions in the
federal government or a specific federal agency. The Security Executive
Agent is responsible for the oversight of investigations and
determinations of eligibility for access to classified information.
[14] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-352T].
[15] GAO, DOD Personnel Clearances: DOD Needs to Overcome Impediments
to Eliminating Backlog and Determining Its Size, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-04-344] (Washington, D.C.: Feb.
9, 2004).
[16] The cost of awarding and maintaining a top secret clearance for 10
years is approximately 30 times greater than the cost of awarding and
maintaining a secret clearance for the same period. For fiscal year
2008, OPM‘s standard billing rate is $3,711 for an investigation for an
initial top secret clearance; $2,509 for an investigation to renew a
top secret clearance, and $202 for an investigation for a secret
clearance. An individual getting a top secret clearance for the first
time and keeping the clearance for 10 years would cost the government a
total of $6,202 in current year dollars ($3,711 for the initial
investigation and $2,509 for the reinvestigation after the first 5
years). In contrast, an individual receiving a secret clearance and
maintaining it for 10 years would result in a total cost to the
government of $202 ($202 for the initial clearance that is good for 10
years). The investigative workload is also affected by the scope of
coverage in the various types of investigations. Much of the
information for a secret clearance is gathered through electronic
files. The investigation for a top secret clearance; however, requires
the information needed for the secret clearance as well as additional
data gathered through time-consuming tasks such as interviews with the
subject of the investigation request, references in the workplace, and
neighbors. Since (1) the average investigative report for a top secret
clearance takes about 10 times as many investigative staff hours as the
average investigative report for a secret clearance, and (2) the top
secret clearance must be renewed twice as often as the secret, the
investigative workload increases about 20-fold. Additionally, the
adjudicative workload increases about 4-fold. In 2007, DOD officials
estimated that it took about twice as long to review an investigative
report for a top secret clearance, which would need to be done twice as
often as for a secret clearance.
[17] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-352T].
[18] GAO, DOD Personnel: Inadequate Personnel Security Investigations
Pose National Security Risks, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO/NSIAD-00-12] (Washington, D.C.: Oct. 27, 1999); and GAO,
DOD Personnel Clearances: Government Plan Addresses Some Long-standing
Problems with DOD‘s Program, but Concerns Remain, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-06-233T] (Washington, D.C.: Nov.
9, 2005).
[19] GAO, DOD Personnel Clearances: Additional OMB Actions Are Needed
to Improve the Security Clearance Process, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-06-1070] (Washington, D.C.: Sept.
28, 2006).
[20] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-1070].
[21] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-233T].
[22] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-352T].
[23] GAO, DOD Personnel: Inadequate Personnel Security Investigations
Pose National Security Risks, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO/NSIAD-00-12] (Washington, D.C.: Oct. 27, 1999).
[24] The National Commission on Terrorist Attacks Upon the United
States, The 9/11 Commission Report: Final Report of the National
Commission on Terrorist Attacks Upon the United States, Government
Printing Office (Washington, D.C.: July 22, 2004).
[End of section]
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