Personnel Security Clearances
Progress Has Been Made to Improve Timeliness but Continued Oversight Is Needed to Sustain Momentum Gao ID: GAO-11-65 November 19, 2010In light of long-standing problems with delays and backlogs, Congress mandated personnel security clearance reforms through the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA). These included requirements related to timeliness, reciprocity, and the creation of a single database to house personnel security clearance information. In 2008, Executive Order 13467 established the Performance Accountability Council. GAO was asked to review the extent to which executive branch agencies (1) investigate and adjudicate personnel security clearance applications in a timely manner, (2) honor previously granted security clearances, and (3) share personnel security clearance information in a single, integrated database. GAO reviewed and analyzed Performance Accountability Council timeliness data for fiscal year 2009 and the first three quarters of fiscal year 2010. GAO also examined key clearance reform documents and conducted interviews with executive branch agencies, including members of the Intelligence Community, to discuss the three stated objectives.
Significant overall progress has been made to improve the investigation and adjudication of personnel security clearance applications in a timely manner. This is largely attributable to the Department of Defense (DOD), whose clearances comprise a vast majority of governmentwide initial clearances. IRTPA establishes an objective for all agencies to make a determination on at least 90 percent of all applications for a personnel security clearance within an average of 60 days. The majority of clearances are processed in line with the IRTPA 60-day objective. Certain agencies, however, continue to face challenges for meeting timeliness objectives. Out of the 14 agencies included in GAO's review, DOD, the Department of Energy, and the National Geospatial-Intelligence Agency met the IRTPA 60-day timeliness objective in the first three quarters of fiscal year 2010. Timeliness among the other executive branch agencies ranged from 62 to 154 days. IRTPA and the recent Intelligence Authorization Act for Fiscal Year 2010 also require annual reporting on the progress made towards meeting objectives, including a discussion of impediments related to timeliness and quality. While the Performance Accountability Council has taken steps to assist in implementation of reform efforts, it has not reported on the impediments to meeting timeliness objectives for specific agencies not yet achieving this goal. Executive branch agency officials stated that they often honor previously granted personnel security clearances (i.e., grant reciprocity), but the true extent of reciprocity is unknown because governmentwide metrics do not exist. IRTPA generally requires that all personnel security clearance investigations and determinations be accepted by all agencies, with limited exceptions when necessary for national security purposes. Agency officials stated that they grant reciprocity, but some noted that they have taken steps to obtain additional information before granting reciprocity. For example, officials stated that they may request copies of background investigation reports before they will honor a security clearance because information available in databases contain limited, summary level detail. Agency officials also reported that steps must be taken to conduct suitability determinations to ensure an applicant's character is appropriate for the position. The extent to which reciprocity is occurring is unknown because no metrics exist to consistently and comprehensively track reciprocity. Although there are no plans to develop a single, integrated database, steps have been taken to upgrade existing systems and increase information sharing. The Performance Accountability Council has opted to leverage existing systems in lieu of the single, integrated database required by IRTPA. Officials assert that a single database is not a viable option due to concerns related to privacy, security, and data ownership. Therefore, a single search capability of existing databases is being used to address the IRTPA requirement. For example, information from two primary databases can now be accessed from a single entry point, allowing executive branch agencies to share clearance information with one another. The Intelligence Community agencies share information through a separate database. GAO recommends that the Performance Accountability Council collaborate with executive agencies to develop a plan to improve timeliness for those agencies not yet achieving the 60-day timeliness objective and metrics to track reciprocity. In commenting on this draft, the Performance Accountability Council concurred with all recommendations.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Brenda S. Farrell Team: Government Accountability Office: Defense Capabilities and Management Phone: (202) 512-3604GAO-11-65, Personnel Security Clearances: Progress Has Been Made to Improve Timeliness but Continued Oversight Is Needed to Sustain Momentum
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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
November 2010:
Personnel Security Clearances:
Progress Has Been Made to Improve Timeliness but Continued Oversight
Is Needed to Sustain Momentum:
GAO-11-65:
GAO Highlights:
Highlights of GAO-11-65, a report to congressional requesters.
Why GAO Did This Study:
In light of long-standing problems with delays and backlogs, Congress
mandated personnel security clearance reforms through the Intelligence
Reform and Terrorism Prevention Act of 2004 (IRTPA). These included
requirements related to timeliness, reciprocity, and the creation of a
single database to house personnel security clearance information. In
2008, Executive Order 13467 established the Performance Accountability
Council. GAO was asked to review the extent to which executive branch
agencies (1) investigate and adjudicate personnel security clearance
applications in a timely manner, (2) honor previously granted security
clearances, and (3) share personnel security clearance information in
a single, integrated database. GAO reviewed and analyzed Performance
Accountability Council timeliness data for fiscal year 2009 and the
first three quarters of fiscal year 2010. GAO also examined key
clearance reform documents and conducted interviews with executive
branch agencies, including members of the Intelligence Community, to
discuss the three stated objectives.
What GAO Found:
Significant overall progress has been made to improve the
investigation and adjudication of personnel security clearance
applications in a timely manner. This is largely attributable to the
Department of Defense (DOD), whose clearances comprise a vast majority
of governmentwide initial clearances. IRTPA establishes an objective
for all agencies to make a determination on at least 90 percent of all
applications for a personnel security clearance within an average of
60 days. The majority of clearances are processed in line with the
IRTPA 60-day objective. Certain agencies, however, continue to face
challenges for meeting timeliness objectives. Out of the 14 agencies
included in GAO‘s review, DOD, the Department of Energy, and the
National Geospatial-Intelligence Agency met the IRTPA 60-day
timeliness objective in the first three quarters of fiscal year 2010.
Timeliness among the other executive branch agencies ranged from 62 to
154 days. IRTPA and the recent Intelligence Authorization Act for
Fiscal Year 2010 also require annual reporting on the progress made
towards meeting objectives, including a discussion of impediments
related to timeliness and quality. While the Performance
Accountability Council has taken steps to assist in implementation of
reform efforts, it has not reported on the impediments to meeting
timeliness objectives for specific agencies not yet achieving this
goal.
Executive branch agency officials stated that they often honor
previously granted personnel security clearances (i.e., grant
reciprocity), but the true extent of reciprocity is unknown because
governmentwide metrics do not exist. IRTPA generally requires that all
personnel security clearance investigations and determinations be
accepted by all agencies, with limited exceptions when necessary for
national security purposes. Agency officials stated that they grant
reciprocity, but some noted that they have taken steps to obtain
additional information before granting reciprocity. For example,
officials stated that they may request copies of background
investigation reports before they will honor a security clearance
because information available in databases contain limited, summary
level detail. Agency officials also reported that steps must be taken
to conduct suitability determinations to ensure an applicant‘s
character is appropriate for the position. The extent to which
reciprocity is occurring is unknown because no metrics exist to
consistently and comprehensively track reciprocity.
Although there are no plans to develop a single, integrated database,
steps have been taken to upgrade existing systems and increase
information sharing. The Performance Accountability Council has opted
to leverage existing systems in lieu of the single, integrated
database required by IRTPA. Officials assert that a single database is
not a viable option due to concerns related to privacy, security, and
data ownership. Therefore, a single search capability of existing
databases is being used to address the IRTPA requirement. For example,
information from two primary databases can now be accessed from a
single entry point, allowing executive branch agencies to share
clearance information with one another. The Intelligence Community
agencies share information through a separate database.
What GAO Recommends:
GAO recommends that the Performance Accountability Council collaborate
with executive agencies to develop a plan to improve timeliness for
those agencies not yet achieving the 60-day timeliness objective and
metrics to track reciprocity. In commenting on this draft, the
Performance Accountability Council concurred with all recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-11-65] or key
components. For more information, contact Brenda S. Farrell at (202)
512-3604 or farrellb@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Significant Overall Progress Has Been Made to Improve Timeliness, but
Some Executive Agencies Continue to Face Challenges in Meeting
Timeliness Objectives:
Executive Agencies Often Grant Reciprocity, Although Challenges Exist
to Measuring and Tracking Reciprocity:
Although There Are No Plans to Develop a Single, Integrated Database,
Steps Have Been Taken to Upgrade Existing Systems and Increase
Information Sharing:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Office of the Director of National
Intelligence:
Appendix III: Comments from the Office of Personnel Management:
Appendix IV: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Figures:
Figure 1: Key Events Related to the Security Clearance Reform Effort:
Figure 2: Timeliness for the First Three Quarters of Fiscal Year 2010:
Average of the Fastest 90 Percent of Initial Clearance Cases for
Select Executive Branch Agencies:
Abbreviations:
DOD: Department of Defense:
e-QIP: electronic Questionnaires for Investigations Processing:
GAO: Government Accountability Office:
IRTPA: Intelligence Reform and Terrorism Prevention Act of 2004:
ODNI: Office of the Director of National Intelligence:
OMB: Office of Management and Budget:
OPM: Office of Personnel Management:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
November 19, 2010:
The Honorable Anna G. Eshoo:
Chairwoman:
Subcommittee on Intelligence Community Management:
Permanent Select Committee on Intelligence:
House of Representatives:
The Honorable Rush D. Holt:
House of Representatives:
Personnel security clearances allow government and industry personnel
to gain access to classified information that, through unauthorized
disclosure, can in some cases cause exceptionally grave damage to U.S.
national security. The July 2010 and subsequent October 2010 reported
unauthorized leak, of almost 500,000 classified documents posted to
the Internet, related to the ongoing wars in Afghanistan and Iraq
highlights the inherent risks involved when granting an individual a
security clearance. Following the terrorist attacks on September 11,
2001, the nation's defense and intelligence needs grew, prompting
increased demand for personnel with security clearances. Accompanying
this increase in demand for clearances have been problems of delays
and backlogs in the personnel security clearance process. In 2005, GAO
first designated the Department of Defense's (DOD) personnel security
clearance program a high-risk area because of these delays and
backlogs.[Footnote 1] We continued that designation in our 2007 and
2009 updates to our high-risk list because delays continued and we
found problems with the quality of investigation and adjudication
documentation.[Footnote 2] For example, in our previous work, we noted
that the average time to complete the fastest 90 percent of initial
clearances for military and DOD civilians was 124 days.[Footnote 3] We
have initiated additional work to assess DOD's personnel security
clearance program and plan to issue our next high-risk report in
January 2011.
In light of long-standing concerns regarding delays in processing
clearances and other issues, Congress set objectives and established
requirements for improving the clearance process in section 3001 of
the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA).
[Footnote 4] IRTPA established objectives for timeliness, requirements
for reciprocity (i.e., an agency's acceptance of a background
investigation or clearance determination completed by any authorized
investigative or adjudicative agency), and an integrated, secure
database to house clearance information. In 2007, DOD and the Office
of the Director of National Intelligence (ODNI) formed the Joint
Security Clearance Process Reform Team, known as the Joint Reform
Team, to improve the security clearance process governmentwide.
[Footnote 5] In the following year, Executive Order 13467 was issued,
establishing a Suitability and Security Clearance Performance
Accountability Council (Performance Accountability Council) that is
responsible for driving the implementation of reform and accountable
to the President for achieving the reform effort's goals. We have
previously noted that top leadership must be committed to
organizational transformation.[Footnote 6] To this end, committed
executive leadership has worked to reform the personnel security
clearance process by improving timeliness and developing quality
measures. However, four years after IRTPA was enacted, the House
Permanent Select Committee on Intelligence, Subcommittee on
Intelligence Community Management, concluded that the federal
government's progress with respect to IRTPA requirements for
reciprocity and a single integrated database had fallen short of the
goals established in IRTPA.[Footnote 7]
Congressional oversight through hearings held by the Subcommittee on
Intelligence Community Management in February, July, and September
2008, and October 2009, has helped focus attention on the need for
security clearance reform.[Footnote 8] In addition, the Intelligence
Authorization Act for Fiscal Year 2010 requires reports by the
President on the security clearance process, including information on
timeliness and quality.[Footnote 9] In this context and building on
our body of work examining personnel security clearance issues, you
asked us to examine the ongoing reform effort with an emphasis on
whether the current reform efforts were expediting the processing of
clearances and enhancing reciprocity.[Footnote 10] Specifically, this
report provides information on the extent to which select executive
branch agencies (1) investigate and adjudicate initial personnel
security clearance applications for civilians, military, and industry
personnel in a timely manner; (2) honor previously granted personnel
security clearances and the challenges, if any, that exist related to
reciprocity; and (3) share personnel clearance information in a
single, integrated database.
In conducting this review, we focused our scope on DOD, seven agencies
within the Intelligence Community,[Footnote 11] and a non-probability
sample of six additional executive branch agencies [Footnote 12] that
use the Office of Personnel Management (OPM) to conduct background
investigations.[Footnote 13] The total sample of executive branch
agencies represents 25 different DOD and non-DOD organizations.
[Footnote 14] According to data contained in the Performance
Accountability Council's 2010 report to Congress on clearances granted
in calendar year 2009, the 14 agencies we selected in our timeliness
review account for approximately 98 percent of initial clearance cases
governmentwide annually.[Footnote 15] To assess the extent to which
executive branch agencies investigate and adjudicate initial personnel
security clearance applications for civilians, military, and industry
personnel in a timely manner we conducted interviews with relevant
officials to discuss aspects of timeliness, including variations in
agency timeliness, progress made, and challenges faced. We analyzed
the timeliness objectives specified in IRTPA and the timeliness data
contained in the Performance Accountability Council's 2010 report to
Congress on clearances granted in calendar year 2009.[Footnote 16] We
obtained and reviewed quarterly data on executive branch agencies,
including Intelligence Community agencies, provided by the Performance
Accountability Council Subcommittee on Performance Management and
Measures, which covered the first through third quarters of fiscal
year 2010.[Footnote 17] These data were current as of August 2010. We
also obtained and reviewed quarterly data for the executive branch
agencies provided by OPM for the same time periods. The Performance
Accountability Council reported agency timeliness data using two
distinct methodologies. First, they calculated IRTPA timeliness by
analyzing investigation and adjudication data separately, calculating
the average timeliness of the fastest 90 percent of investigations and
adjudications based on the fiscal quarter that the phase was reported
as complete, and combining the timeliness data for the averages of
investigations with the averages for adjudications by agency. The
second methodology used by the Performance Accountability Council
addressed only cases that were completed in the specific period. Under
this methodology, the Performance Accountability Council calculated
the "end-to-end" timeliness, which they defined as the time for an
individual case to go through the initiation, investigation, and
adjudication phases of the process. GAO utilized this second
methodology to review and analyze the agency timeliness data that is
contained in this report. The Performance Accountability Council
excludes certain cases that could impact overall timeliness from its
analysis. For example, IRTPA establishes a timeliness objective for
the fastest 90 percent of cases, which allows agencies to exclude the
slowest 10 percent of cases from the reported averages. We interviewed
knowledgeable officials about the accuracy and completeness of the
data to determine the reliability of the data. We determined that
these data were sufficiently reliable for our purposes.
To assess the extent to which executive branch agencies honor
previously granted security clearances and the challenges, if any,
that exist related to reciprocity, we reviewed the requirements
specified in IRTPA and analyzed Executive Orders, Office of Management
and Budget (OMB) memorandums, ODNI documents, and agency guidance
related to reciprocity. We also analyzed existing and planned metrics
developed by the Performance Accountability Council to track the
extent to which reciprocity is honored. We met with security officials
and adjudicators from DOD, the Intelligence Community, and a non-
probability sample of executive branch agencies. We supplemented our
analyses with information obtained from a roundtable discussion that
we conducted with representatives of Intelligence Community agencies
to examine the challenges these agencies face related to information
sharing and granting reciprocity. For the purposes of our report, we
define reciprocity as an agency's acceptance of a background
investigation or clearance determination completed by another
authorized investigative or adjudicative agency. We excluded from the
scope of our work issues related to access to facilities, detailed
employees, or access to classified information.
To determine the extent to which select executive branch agencies
share personnel clearance information in a single, integrated
database, we conducted interviews with officials from OPM, DOD, and
Intelligence Community agencies and reviewed OPM database enhancement
plans that described recent developments in information sharing. We
selected OPM, DOD, and agencies within the Intelligence Community
because they own the three main security clearance databases that are
used in the security clearance process.[Footnote 18] To determine the
challenges associated with sharing clearance information in a single,
integrated database, we reviewed the Joint Reform Team's Enterprise
Information Technology Strategy and interviewed agency security
managers and adjudicators who use the existing security clearance
database systems.
We conducted this performance audit from October 2009 through November
2010 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our objectives. More detailed
information on our scope and methodology is provided in appendix I.
Results in Brief:
Significant overall progress has been made to improve the
investigation and adjudication of personnel security clearance
applications in a timely manner. This is largely attributable to DOD,
whose clearances comprise a vast majority of governmentwide initial
clearances. IRTPA established an objective for each authorized
adjudicative agency to "make a determination on at least 90 percent of
all applications for a personnel security clearance within an average
of 60 days from the date of receipt of the completed application by an
authorized investigative agency" by December 17, 2009.[Footnote 19]
Although the majority of clearances are processed in line with the
IRTPA 60-day objective, agencies continue to face challenges for
meeting timeliness objectives. According to the Performance
Accountability Council's February 2010 annual report to Congress, five
of the 14 agencies we included in our review met the IRTPA 60-day
objective in the first quarter of fiscal year 2010.[Footnote 20] We
found that four agencies met the objective in the second quarter and
seven agencies met the objective in the third quarter.[Footnote 21]
The Department of Defense, the Department of Energy, and the National
Geospatial-Intelligence Agency met the IRTPA 60-day timeliness
objective in all three quarters. We found a number of challenges to
agencies meeting IRTPA timeliness objectives, including personnel
limitations, variances among the agencies in adopting information
technology caused by resource constraints, and additional agency-
specific requirements that must be met before granting a security
clearance. Agency officials with whom we spoke explained that there is
a variance in agencies' adoption of the Electronic Questionnaires for
Investigations Processing (e-QIP). According to these officials, e-QIP
has sped up investigation timeliness for agencies that have adopted
this technology because it provides OPM with more complete and better
quality data earlier in the process. Agency officials also discussed
the delays in adjudicative timeliness due to the need to follow up on
investigations performed by OPM. Finally, timeliness for the
Intelligence Community is affected by unique issues related to
conditions of employment that require polygraphs or psychological
evaluations that extend beyond the standard background investigation.
IRTPA also requires the executive branch to submit an annual report,
through 2011, to the appropriate congressional committees on the
progress made toward meeting its requirements, including timeliness
data and a discussion of any impediments to the smooth and timely
functioning of its requirements.[Footnote 22] While the Performance
Accountability Council, responsible for driving implementation of the
reform effort and ensuring accountability, has taken steps to assist
in implementation of reform efforts, it has not reported on the
impediments to meeting timeliness objectives or plans to address
impediments. As a result, decision makers may not have a complete
picture of the progress made or the impediments to meeting timeliness
objectives. We recommend that the Deputy Director of Management, OMB,
in the capacity as Chair of the Performance Accountability Council,
direct the Performance Accountability Council to collaborate with the
agencies that are not meeting timeliness objectives to take the
following actions: (1) identify challenges to timeliness, (2) develop
mitigation strategies to enable each agency to comply with the IRTPA
timeliness objectives, (3) set timelines for accomplishing the
required actions, (4) monitor agency progress, and (5) report on these
plans and progress in the annual reports to Congress.
Agency officials stated that they routinely take steps to honor
previously granted security clearances; however, there are no
governmentwide metrics to comprehensively track when and why
reciprocity is granted or denied. IRTPA generally requires that all
security clearance investigations and determinations be accepted by
all agencies, with limited exceptions when necessary for national
security purposes.[Footnote 23] Further, ODNI guidance signed out in
October 2008 amplifies this reciprocity requirement, stating that,
except in limited circumstance, all Intelligence Community elements
should "accept all in-scope security clearance or access
determinations."[Footnote 24] Similarly, OMB issued guidance requiring
agencies to reciprocally accept clearances when the prior clearance is
current and there is no new derogatory information, among other
things.[Footnote 25] However, agency officials stated that in some
cases, they find it necessary to take additional steps to address
limitations with available information before granting a reciprocal
clearance. For example, because no single, integrated database exists
and information currently being shared between agencies may be
insufficient, agencies request additional information, such as copies
of the original background investigation. Similarly, because of the
different types of background investigations required by individual
agencies, agencies may perform additional investigative work or
request a new background investigation. In addition, agency officials
identified broader challenges to granting reciprocity, such as the
need to conduct suitability determinations or determine whether a
prior clearance investigation and adjudication meets standards. All
federal agencies are required to conduct basic suitability
determinations to ensure that the applicant's character or conduct is
appropriate for the position in question. However, some agencies have
specific requirements to determine suitability before reciprocating a
security clearance, according to agency officials with whom we spoke.
While the Performance Accountability Council has identified
reciprocity as a governmentwide strategic goal, we found that there is
no clear evidence to show the extent to which reciprocity is granted
because agencies lack comprehensive, standardized metrics to track
reciprocity. We previously reported that developing metrics for
assessing and regularly monitoring all aspects of the clearance
process could add value in current and future reform efforts as well
as supply better information for greater congressional oversight.
[Footnote 26] However, we found that agencies do not consistently
document the additional steps they have taken prior to granting a
reciprocal clearance. For example, the Navy keeps electronic
documentation, the Department of Energy and the Department of the
Treasury keep paper documentation, and the Army and the Air Force do
not maintain any documentation on the additional steps taken to accept
a previously granted security clearance. Consequently, there is no
consistent tracking of the amount of staff time spent on the
additional actions that are taken to honor a previously granted
security clearance. In addition, we found agencies do not consistently
and comprehensively track the extent to which reciprocity is granted.
While OPM has a metric to track reciprocity, this metric captures
limited information, such as numbers of requested and rejected
investigations, but not the number of cases in which a previously
granted security clearance was or was not honored. Similarly, the
metrics proposed by the Performance Accountability Council do not
track the extent to which reciprocity is or is not ultimately honored.
Without comprehensive, standardized metrics to track reciprocity, and
documentation of the process, decision makers lack a complete picture
of the extent to which reciprocity is granted and the challenges to
honoring security clearances. We recommend that the Deputy Director of
Management, OMB, in the capacity as Chair of the Performance
Accountability Council, develop comprehensive metrics to track
reciprocity and report the findings from the expanded tracking to
Congress.
Although IRTPA required the establishment of a single, integrated
database, executive branch agencies have opted to focus on leveraging
existing systems rather than establish a new database. IRTPA required
that, not later than 12 months after the date of enactment of the act,
the Director of the Office of Personnel Management and the Director of
the Office of Management and Budget establish and commence operating
and maintaining a single, integrated database of personnel security
clearance information.[Footnote 27] Based on our analyses of a series
of recent reports that the Joint Reform Team, under the Performance
Accountability Council, issued between 2008 and 2010, and interviews
conducted with OPM and ODNI officials, we found that there are no
plans to create a new single, integrated database. OPM, DOD, and ODNI
officials with whom we spoke explained that establishing a single,
integrated database is not a viable option due to concerns related to
privacy, security, and data ownership. Therefore, the Performance
Accountability Council is focusing on using a single search capability
of existing databases as the means by which they intend to address the
IRTPA requirement. Although there are no plans to create a new
governmentwide database, we found that non-intelligence agencies in
our review are sharing information about personnel who hold or are
seeking security clearances through two main databases that can be
accessed through a single entry point. These two primary databases are
used by non-intelligence agencies to store investigative and
adjudicative information and according to the Performance
Accountability Council, they account for decisions on about 90 percent
of all security clearance holders in the federal government.[Footnote
28] Data is stored in either OPM's Central Verification System or
DOD's Joint Personnel Adjudication System. Data from the two databases
can be searched from a single entry point in the Central Verification
System. In contrast, the Intelligence Community agencies share
information with one another through a separate classified database
known as Scattered Castles. According to Performance Accountability
Council officials, the Performance Accountability Council is
participating in an effort to explore ways to enhance information
sharing between the Intelligence Community agencies and the non-
Intelligence Community agencies. For example, a working group has been
established to study alternatives to support a single-access point
from which non-intelligence agencies can obtain clearance information
and plans to complete its review in December 2010.
In oral and written comments on a draft of this report, the OMB, ODNI,
and OPM concurred with all of our recommendations. In particular, ODNI
noted that it was already taking steps through the Performance
Accountability Council to implement each recommendation. OMB, ODNI,
DOD, and OPM also provided technical comments, which we incorporated
into this report, as appropriate.
Background:
Personnel security clearances are required for access to certain
national security information, which may be classified at one of three
levels: confidential, secret, or top secret. A top secret clearance is
generally also required for access to Sensitive Compartmented
Information or Special Access Programs[Footnote 29]. The level of
classification denotes the degree of protection required for
information and the amount of damage that unauthorized disclosure
could reasonably be expected to cause to national security.
Unauthorized disclosure could reasonably be expected to cause (1)
"damage," in the case of confidential information; (2) "serious
damage," in the case of secret information; and (3) "exceptionally
grave damage," in the case of top secret information. To ensure the
trustworthiness and reliability of personnel in positions with access
to classified information, government agencies rely on a multiphased
personnel security clearance process that includes the application
submission phase, investigation phase, and adjudication phase.
* The application submission phase. A security officer from an agency
(1) requests an investigation of an individual requiring a clearance;
(2) forwards a personnel security questionnaire (standard form 86)
using OPM's e-QIP system or a paper copy of the standard form 86 to
the individual to complete; (3) reviews the completed questionnaire;
and (4) sends the questionnaire and supporting documentation, such as
fingerprints, to OPM or the investigation service provider.
* The investigation phase. Federal investigative standards and OPM's
internal guidance are used to conduct and document the investigation
of the applicant.[Footnote 30] The scope of information gathered in an
investigation depends on the level of clearance needed and whether an
investigation for an initial clearance or reinvestigation for a
clearance renewal is being conducted.[Footnote 31] For example, the
federal standards require that investigators collect information from
national agencies, such as the Federal Bureau of Investigation, for
all initial and renewal clearances. For an investigation for a
confidential or secret clearance, investigators gather much of the
information electronically. For an investigation for a top secret
clearance, investigators gather additional information through more
time-consuming efforts, such as traveling to conduct in-person
interviews to corroborate information about an applicant's employment
and education. After the investigation is complete, the resulting
investigative report is provided to the agency. According to the
Performance Accountability Council's Strategic Framework, for the
purposes of IRTPA timeliness reporting, investigative time is the time
in days from the receipt date of the completed personnel security
package by the investigative service provider to the date the final
investigative file is forwarded to the adjudicative facility if sent
electronically.
* The adjudication phase. Adjudicators from an agency use the
information from the investigative report to determine whether an
applicant is eligible for a security clearance. To make clearance
eligibility decisions, federal requirements specify that adjudicators
consider guidelines in 13 specific areas that elicit information about
(1) conduct that could raise security concerns and (2) factors that
could allay those security concerns and permit granting a clearance.
According to the Performance Accountability Council's Strategic
Framework, for the purposes of IRTPA timeliness reporting,
adjudicative time is the time in days from the date the final
investigative file is forwarded (or received electronically) to the
adjudicative unit to the date of the adjudicative decision.
* Separate from, but related to, security clearances, are suitability
determinations. Executive branch agencies conduct additional
suitability investigations for individuals to ensure that they are
suitable for employment in certain positions.[Footnote 32] For
example, the Department of Justice conducts additional suitability
checks to ensure applicants for jobs with the Drug Enforcement Agency
have not used drugs. In addition, Health and Human Services conducts
additional suitability investigations on applicants for jobs working
with children. Similarly, the Intelligence Community requires a
polygraph evaluation, among other things, to determine suitability for
most positions.
In light of long-standing delays and backlogs in processing security
clearances, Congress set goals and established requirements for
improving the clearance process in the Intelligence Reform and
Terrorism Prevention Act of 2004. In 2005, GAO designated DOD's
personnel security clearance program as a high risk area.[Footnote 33]
As can be seen in figure 1, a number of steps have been taken to
reform the process, including:
* Role of the Office of Management and Budget in security clearance
process. In June 2005, the President issued an executive order as part
of the administration's efforts to improve the security clearance
process and implement the statutory clearance requirements in
IRTPA.[Footnote 34] This order tasked the Director of OMB with a
variety of functions in order to ensure that agency processes relating
to determining eligibility for access to classified national security
information were appropriately uniform, centralized, efficient,
effective, timely, and reciprocal. These actions included taking a
lead role in preparing a November 2005 plan to improve the timeliness
of personnel security clearance processes governmentwide.
* Formation of the Joint Reform Team. The Joint Security Process
Reform Team, also known as the Joint Security and Suitability Reform
Team or Joint Reform Team, formed in June 2007, was established by the
Director of National Intelligence and Under Secretary of Defense for
Intelligence through a memorandum of agreement to execute joint reform
efforts to achieve IRTPA timeliness goals and improve the processes
related to granting security clearances and determining suitability
for government employment. Agencies included in this governmentwide
reform effort are ODNI, DOD, OMB, and OPM. The Joint Reform Team
continues to work on the reform effort under the Performance
Accountability Council by providing progress reports, recommending
research priorities, and overseeing the development and implementation
of an information technology strategy, among other things. Since its
formation, the Joint Reform Team under the Performance Accountability
Council:
(1) Submitted an initial reform plan to the President on April 30,
2008. The plan proposed a new process for determining clearance
eligibility that departs from the current system in a number of ways,
including the use of a more sophisticated electronic application, a
more flexible investigation process, and the establishment of ongoing
evaluation procedures between formal clearance investigations. The
report was updated in December 2008 to include an outline of reform
progress and further plans.
(2) Issued an Enterprise Information Technology Strategy to support
the reformed security and suitability process in March 2009. According
to the report, the Joint Reform Team is pursuing an approach that
leverages existing systems and capabilities, where applicable, and
developing new tools where necessary.
* Formation of the Performance Accountability Council. Executive Order
13467 established the leadership structure for security and
suitability reform headed by the Suitability and Security Clearance
Performance Accountability Council as the entity responsible for
aligning security and suitability, holding agencies accountable for
implementation, and overseeing progress toward the reformed vision.
[Footnote 35] This executive order directed, among other things, that
executive branch policies and procedures be aligned and use consistent
standards, to the extent possible, for investigating and adjudicating
whether an individual is (1) suitable for government employment, (2)
fit to be a contract employee, or (3) eligible for access to
classified information. The Performance Accountability Council is
accountable to the President to achieve reform goals and also oversees
newly designated Security and Suitability Executive Agents. The
executive order designated the Director of National Intelligence as
the Security Executive Agent, the Director of OPM as the Suitability
Executive Agent, and the Deputy Director for Management at OMB as the
chair of the council with the authority to designate officials from
additional agencies to serve as members. The council currently
comprises representatives from 11 executive agencies. In May 2010, the
Performance Accountability Council proposed quality measures to
address the different phases of the application process including
validating need, e-application, investigation, and adjudication. The
measures also include the responsible organization, population
covered, collection method, and whether it is a current or future
measure.
* Strategic Framework. The Performance Accountability Council issued a
Strategic Framework in February 2010 to articulate the goals of the
security and suitability process reform. The Strategic Framework sets
forth a mission and strategic goals, performance measures, a
communications strategy, roles and responsibilities, and metrics to
measure the quality of security clearance investigations and
adjudications.
Figure 1: Key Events Related to the Security Clearance Reform Effort:
[Refer to PDF for image: time line]
December 17, 2004:
Intelligence Reform and Terrorist Prevention Act passed.
January 2005:
Government Accountability Office places Department of Defense‘s
clearance program on its high-risk list.
June 27, 2005:
Executive Order 13881 designates the Office of Management and Budget
the single entity to ensure centralization, uniformity, and
reciprocity of security clearance policies.
November 2005:
Office of Management and Budget issues a plan for improving the
security clearance process.
June 25, 2007:
The Joint Reform Team is formed to develop a plan for clearance
reform, including research priorities and an information technology
strategy, to achieve IRTPA goals.
April 30, 2008:
The Joint Reform Team issues a report on reforming the security
clearance and suitability process.
December 18, 2008:
The Joint Reform Team issues a report outlining reform progress and
further plans.
June 30, 2008:
Executive Order 13467 establishes the Performance Accountability
Council to drive implementation of the reform effort and designated
the Office of Management and Budget‘s Deputy Director for Management
as Chair.
March 17, 2009:
The Joint Reform Team issues an Enterprise Information Technology
Strategy to support the reformed security and suitability process.
February 16, 2010:
The Performance Accountability Council issues a strategic framework to
articulate the goals of the security and suitability process reform.
May 31, 2010:
The Performance Accountability Council develops quality measures[A]
that it believes will identify specific quantifiable targets linked to
goals that are intended to be measured objectively and ultimately
gauge progress and assess the quality of the personnel security
clearance process.
Source: GAO analysis.
[A] The Quality Measures are proposed measures.
[End of figure]
Significant Overall Progress Has Been Made to Improve Timeliness, but
Some Executive Agencies Continue to Face Challenges in Meeting
Timeliness Objectives:
Timeliness Varies Across Agencies:
The government has reported that significant overall progress has been
made to improve the investigation and adjudication of personnel
security clearance applications in a timely manner. This is largely
attributable to DOD, whose clearances comprise a vast majority of
governmentwide initial clearances. IRTPA required the executive branch
to develop a plan under which, to the extent practical, each
authorized adjudicative agency would be required to make a
determination on at least 90 percent of initial security clearances
within an average of 60 days by December 17, 2009.[Footnote 36] Within
this 60-day period, IRTPA also includes periods of 40 days for
investigations and 20 days for adjudications.[Footnote 37] As can be
seen in figure 2, according to the Performance Accountability
Council's February 2010 annual report to Congress,[Footnote 38] during
the first quarter of fiscal year 2010, two agencies--the National
Geospatial-Intelligence Agency and the National Reconnaissance Office--
met the timeliness requirement for investigations, seven agencies--the
Departments of Defense, Energy, Health and Human Services, the Defense
Intelligence Agency, the National Security Agency, the Federal Bureau
of Investigation, and the Department of State--met the timeliness
objectives for adjudications, and five agencies--the Department of
Defense, Department of Energy, the National Geospatial-Intelligence
Agency, the National Reconnaissance Office, and the Department of
State--met the 60-day IRTPA timeliness objective.[Footnote 39]
Furthermore, we found that one of the agencies included in our review--
the National Geospatial-Intelligence Agency--met all of the IRTPA
timeliness objectives for the second and third quarter, while the
Defense Intelligence Agency met all of the IRTPA timeliness objectives
in the second quarter and DOD, which comprises the vast majority of
clearances, and the Federal Bureau of Investigation, met all of the
IRTPA timeliness objectives in the third quarter of fiscal year 2010.
We also found that timeliness varied widely among executive branch
agencies. During the first three quarters of fiscal year 2010, the
average for the fastest 90 percent of cases adjudicated by the 14
agencies included in our review ranged from 22 to 96 days for
investigation timeliness, 2 to 59 days for adjudication timeliness,
and 30 to 154 days for IRTPA timeliness.[Footnote 40] Agency officials
that we spoke with largely attributed the wide variation between these
agencies to variances in the adoption of information technology.
According to OPM officials, timeliness varies for the agencies that
use OPM as the investigative service provider due, in part, to
differences in agency adoption of information technology, such as the
e-QIP that speeds up investigation timeliness by providing OPM with
more complete and better quality data earlier in the process.[Footnote
41] With regard to adjudication timeliness, five of the agencies we
included in our review have developed electronic delivery, electronic
adjudication, or case management and workflow tools to improve
timeliness, while others have not.
Figure 2: Timeliness for the First Three Quarters of Fiscal Year 2010:
Average of the Fastest 90 Percent of Initial Clearance Cases for
Select Executive Branch Agencies:
[Refer to PDF for image: illustrated table]
No delegated authority[A]:
Department of Defense[B]:
Investigations (40 days):
First quarter: 42 days;
Second quarter: 45 days;
Third quarter: [Check];
Adjudication (20 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Combined (60 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check].
Department of Homeland Security:
Investigations (40 days):
First quarter: 48 days;
Second quarter: 51 days;
Third quarter: 49 days;
Adjudication (20 days):
First quarter: 48 days;
Second quarter: 59 days;
Third quarter: 57 days;
Combined (60 days):
First quarter: 96 days;
Second quarter: 110 days;
Third quarter: 106 days.
Department of Energy:
Investigations (40 days):
First quarter: 47 days;
Second quarter: 45 days;
Third quarter: 44 days;
Adjudication (20 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Combined (60 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check].
Department of Justice:
Investigations (40 days):
First quarter: 60 days;
Second quarter: 68 days;
Third quarter: 63 days;
Adjudication (20 days):
First quarter: 42 days;
Second quarter: 44 days;
Third quarter: 28 days;
Combined (60 days):
First quarter: 102 days;
Second quarter: 112 days;
Third quarter: 91 days.
Department of the Treasury:
Investigations (40 days):
First quarter: 54 days;
Second quarter: 56 days;
Third quarter: 52 days;
Adjudication (20 days):
First quarter: 54 days;
Second quarter: 27 days;
Third quarter: 46 days;
Combined (60 days):
First quarter: 108 days;
Second quarter: 83 days;
Third quarter: 98 days.
Department of Health and HUman Services:
Investigations (40 days):
First quarter: 52 days;
Second quarter: 53 days;
Third quarter: 47 days;
Adjudication (20 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Combined (60 days):
First quarter: 65 days;
Second quarter: 70 days;
Third quarter: [Check].
Department of Veterans Affairs:
Investigations (40 days):
First quarter: 54 days;
Second quarter: 78 days;
Third quarter: 70 days;
Adjudication (20 days):
First quarter: 31 days;
Second quarter: [Check];
Third quarter: 26 days;
Combined (60 days):
First quarter: 85 days;
Second quarter: 93 days;
Third quarter: 96 days.
Delegated authority[A]:
Defense Intelligence Agency:
Investigations (40 days):
First quarter: 55 days;
Second quarter: [Check];
Third quarter: 49 days;
Adjudication (20 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Combined (60 days):
First quarter: 80 days;
Second quarter: 68 days;
Third quarter: 78 days.
National Security Agency[C]:
Investigations (40 days):
First quarter: 70 days;
Second quarter: 59 days;
Third quarter: 49 days;
Adjudication (20 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Combined (60 days):
First quarter: 80 days;
Second quarter: 68 days;
Third quarter: [Check].
National Geospatial-Intelligence Agency;
Investigations (40 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Adjudication (20 days):
First quarter: 31 days;
Second quarter: [Check];
Third quarter: [Check];
Combined (60 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check].
Central Intelligence Agency:
Investigations (40 days):
First quarter: 78 days;
Second quarter: 85 days;
Third quarter: 96 days;
Adjudication (20 days):
First quarter: 49 days;
Second quarter: 47 days;
Third quarter: 58 days;
Combined (60 days):
First quarter: 127 days;
Second quarter: 132 days;
Third quarter: 154 days.
Federal Bureau of Investigations:
Investigations (40 days):
First quarter: 76 days;
Second quarter: 75 days;
Third quarter: [Check];
Adjudication (20 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Combined (60 days):
First quarter: 82 days;
Second quarter: 78 days;
Third quarter: [Check].
National Reconnaissance Office:
Investigations (40 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Adjudication (20 days):
First quarter: 31 days;
Second quarter: 58 days;
Third quarter: 36 days;
Combined (60 days):
First quarter: [Check];
Second quarter: 85 days;
Third quarter: 62 days.
Department of State:
Investigations (40 days):
First quarter: 43 days;
Second quarter: 47 days;
Third quarter: 48 days;
Adjudication (20 days):
First quarter: [Check];
Second quarter: [Check];
Third quarter: [Check];
Combined (60 days):
First quarter: [Check];
Second quarter: 54 days;
Third quarter: [Check].
Source: Performance Accountability Council data.
[Note: The Data provided by the Performance Accountability Council was
provided in August 2010. We assessed the reliability of the data and
determined that the data are sufficiently reliable for the purposes of
our report.
[A] Agencies without delegated authority rely on OPM to conduct their
background investigations while agencies with delegated authority have
been authorized to conduct their own background investigations. As
such, timeliness data for agencies without delegated authority is a
reflection of OPM's timeliness.
[B] DOD cases account for a vast majority of clearances. The
Performance Accountability Council timeliness reports on initial
clearances include DOD secret/confidential renewal cases. A prior GAO
review and OPM officials' estimates of DOD clearance timeliness in
fiscal year 2009 indicated that confidential and secret level
clearances, whether initial or renewal, generally took the same amount
of time to investigate. Furthermore, the Defense Personnel Security
Research Center--a Department of Defense entity dedicated to improving
the effectiveness, efficiency, and fairness of the DOD personnel
security system--issued a working paper that showed that average
adjudication timeliness did not substantially differ between initial
and renewal secret clearance cases for DOD using first, second, and
third quarter data for fiscal year 2008.
[C] According to National Security Agency officials, due to the nature
of the National Security Agency's initiation and investigation
requirements, reported investigation times include additional steps,
such as suitability determination investigations.
[End of figure]
Agencies Have Made Efforts to Improve Timeliness for Processing
Security Clearances:
The requirements established by IRTPA have resulted in a
governmentwide focus on improving the timeliness of initial security
clearances through the Performance Accountability Council. In
addition, several of the agency officials with whom we spoke reported
that their agencies prioritize timeliness for security clearances. For
example, several agency officials noted that the passage of IRTPA was
an important factor leading to continued senior level leadership
commitment, involvement, and oversight over timeliness reform through
the Performance Accountability Council. Moreover, IRTPA's annual
reporting requirements have provided more information about agency
timeliness to Congress, allowing for more oversight and increasing
transparency and accountability. However, IRTPA does not set
timeliness requirements for suitability determinations, Homeland
Security Presidential Directive-12 investigations,[Footnote 42] and
security clearance renewals. According to agency officials we spoke
to, their agencies often prioritize initial security clearances for
processing.
Governmentwide efforts to improve the timeliness of personnel security
clearance processing have focused on technology solutions. For
example, the Joint Reform Team and the Performance Accountability
Council have encouraged agencies to utilize information technology
solutions, such as e-QIP, electronic delivery, and electronic
adjudication capabilities to enhance automation.[Footnote 43] E-QIP
facilitates more complete collection of a subject's information
upfront in the process and reduces errors, which lowers, on average,
the time it takes for investigators to clarify the information
provided. Electronic delivery reduces the adjudicative phase by
eliminating delays in receiving investigative reports related to mail
and courier services, such as the need at certain agencies to
irradiate all incoming mail. Electronic adjudication systems use
automation to review investigative reports for missing information and
adjudicate the cases, under certain conditions, within seconds. Agency
officials indicated that as agencies have adopted these capabilities,
timeliness improved. In addition, OPM, which performs approximately 94
percent of initial clearance investigations for the federal
government, has also taken steps to improve timeliness. For example,
according to OPM officials, OPM also made information technology
enhancements to improve its processes, such as enabling electronic
delivery.
Aside from these governmentwide efforts, some agency officials stated
that their agencies have taken steps to improve adjudication
timeliness. DOD, for example, developed and implemented an electronic
case management system--the Clearance Adjudication Tracking System--
within several of its Central Adjudication Facilities.[Footnote 44] In
2009, the Army began electronically adjudicating secret clearances
through the Clearance Adjudication Tracking System, which was a
significant factor in improving the Army's adjudicative average
timeliness. For example, according to the Performance Accountability
Council's Strategic Framework, the average of the fastest 90 percent
of initial clearance adjudications for the Army fell from 187 days in
the second quarter of fiscal year 2009 to 10 days in the first quarter
of fiscal year 2010. The Department of Energy also took steps to
enhance timeliness. For example, in addition to utilizing electronic
delivery and e-QIP, the Department of Energy developed corrective
action plans, implemented case prioritization procedures, and created
a tiered adjudication structure to clear easier cases quickly while
utilizing a complex case review board to address complex cases in a
timely manner. In addition, the Department of Energy built timeliness
performance into adjudicator evaluations, reduced the number of people
involved with deciding cases, and increased manpower to meet workload
requirements.
Agencies Continue to Face Several Challenges to Meeting Timeliness
Objectives:
Despite the actions that have been taken to improve timeliness, agency
officials with whom we spoke identified several remaining challenges
to meeting IRTPA's timeliness objectives. These challenges include
agency-specific issues, such as resource constraints and manpower
limitations. For example:
* Resource constraints are a limiting factor for several agencies in
implementing certain information technology capabilities, such as
electronic delivery, case management, and workflow tools. For example,
Defense Intelligence Agency officials indicated that they are
constrained in implementing a key information technology that provides
electronic delivery, case management, and workflow tool capabilities.
Furthermore, some agencies, especially those with relatively small
clearance caseloads, find it difficult to justify large investments to
develop and implement information technology systems.
* Personnel limitations, such as personnel shortages or increased
workloads, were also identified by several agency officials as an
ongoing challenge. Some agency officials stated that their agencies
already have or expect to experience personnel shortages. For example,
officials from the Department of Homeland Security stated that a lack
of resources is the primary issue for not meeting the timeliness
objectives, but the Department of Homeland Security headquarters is
currently backfilling 10 vacant adjudicator positions, which should
help to alleviate the problem. In addition, some agency officials
stated that their agency staff is subject to workload increases, such
as periods of increased agency hiring, spikes in security clearance
renewal cases, or additional duties related to corollary requirements.
For example, in 2008, Homeland Security Presidential Directive-12
directed the implementation of a common governmentwide identification
standard for federal employees and contractors, under which federal
agencies have been required to begin issuing common identification and
access badges for all individuals, including contractors, who need
access to government facilities or computer networks. These badge
requirements, while different from those required for security
clearances, expanded the pool of staff needing investigations and
adjudicative determinations. These issues are particularly challenging
in places where staff already perform clearance processes as a
collateral duty.
We found other challenges to meeting timeliness objectives that were
the result of systemic issues involving interagency and
intergovernmental activities. Agencies are often unable to control
certain processes in order to meet timeliness objectives when they are
dependent on information or action from other governmental entities.
For example:
* Information-sharing between agencies is an ongoing challenge that
can manifest itself in several ways. First, investigative agencies are
not in direct control of the timeliness and completeness of Federal
Bureau of Investigation, state, and local law enforcement fingerprint
and criminal investigation checks. For example, the results of Federal
Bureau of Investigation criminal investigation checks often are
returned with a classification listed as "No Pertinent," which
indicates that there is no pertinent information relevant to making a
clearance eligibility determination. Some agency officials with whom
we spoke indicated that this type of response leaves adjudicators with
incomplete information due to the potential that the designation is
either the result of a subjective judgment from an outside party as to
what they believe is relevant information or a placeholder to indicate
that more information is potentially available, but pending or not
releasable. Second, officials said the lack of digitization of records
at certain federal, state, and local agencies can be a challenge to
gathering information for timely completion of investigations and
adjudicative decisions. When personnel files, for example, are not
stored, catalogued, and made searchable through electronic means,
agencies are limited by manual checks. Finally, delays and incomplete
information may occur in obtaining information from intelligence
agencies. For example, some agency officials with whom we spoke stated
that since they do not have direct access to clearance-related
information and databases for agencies in the Intelligence Community,
they rely upon manual requests for information.
* Investigation services quality and cost is an ongoing challenge to
meeting timeliness objectives, according to agencies officials. For
example, officials representing the Departments of Homeland Security,
Energy, the Treasury, Justice, and four DOD component agencies
[Footnote 45] that utilize OPM as their investigative service provider
cited challenges related to deficient investigative reports as a
factor that slows agencies' abilities to make adjudicative decisions.
The quality and completeness of investigative reports directly affects
adjudicator workloads, including whether additional steps are required
before adjudications can be made, as well as agency costs. For
example, some agency officials we spoke with noted that OPM
investigative reports do not include complete copies of associated
police reports and criminal record checks. According to ODNI and OPM
officials, OPM investigators provide a summary of police and criminal
reports and assert that there is no policy requiring inclusion of
copies of the original records. However, ODNI officials also stated
that adjudicators may want or need entire records as critical elements
may be left out. For example, according to Defense Office of Hearings
and Appeals officials, in one case, an investigator's summary of a
police report incorrectly identified the subject as a thief when the
subject was actually the victim. If the Defense Office of Hearings and
Appeals had access to actual police documents, officials believe the
adjudication process would be more efficient. We noted in our prior
work that documentation was incomplete for most OPM-provided
investigative reports based on independent review of about 3,500
investigative reports.[Footnote 46] We also noted in our previous work
that incomplete investigative documentation may lead to increases in
the time it takes to complete the clearance process and the overall
costs of the process.[Footnote 47] Several agency officials stated
that in order to avoid further costs or delays they often choose to
perform additional steps internally to obtain missing information,
clarify or explain issues identified in investigative reports, or
gather evidence for issue resolution or mitigation.
Finally, a significant challenge to meeting timeliness objectives
specific to Intelligence Community agencies involve addressing the
requirements that are unique to these agencies. For example, since
most positions in Intelligence Community agencies require top secret
clearances with Sensitive Compartmented Information access,
intelligence agencies rely almost exclusively on Single Scope
Background Investigations that are required for these types of
clearances. These investigations have higher requirements for the
types and numbers of sources of information required compared to
investigations for secret or confidential clearances. According to
agency officials, these higher requirements take longer, on average,
to investigate and adjudicate. In addition, timeliness for
intelligence agencies is often complicated by the unique issues
presented by extensive suitability determination processes and precise
conditions of employment that may include medical exams, psychological
evaluations, drug testing, and polygraph exams. Polygraph exams, for
example, may generate additional leads that require further
investigative work. Moreover, agency officials also stated that
scheduling a polygraph with an individual, especially if they live far
from agency offices, may add months to investigation timelines.
Performance Accountability Council Has Not Reported on Impediments to
Meeting Timeliness Objectives or Plans to Address Impediments:
While the Performance Accountability Council, responsible for driving
implementation of the reform effort and ensuring accountability, has
taken steps to assist in implementation of reform efforts, it has not
reported on the impediments to meeting timeliness objectives or plans
to address impediments. IRTPA's security clearance reform provision
requires annual reports to the appropriate congressional committees--
through 2011--on the progress made during the preceding year toward
meeting its requirements, including timeliness data and a discussion
of any impediments to the smooth and timely functioning of its
requirements. However, in its most recent report to Congress, the
Performance Accountability Council did not provide information on the
impediments agencies face in meeting timeliness objectives or plans to
address impediments. While the Office of the Director of National
Intelligence, in its capacity as Security Executive Agent, has
performed a limited number of oversight audits, according to officials
at four agencies we met with, the Performance Accountability Council
has not met with them to identify the impediments to meeting the
timeliness objectives. The Performance Accountability Council has
focused its efforts on DOD in part due to DOD's security clearance
program's designation as one of GAO's high-risk areas, as well as the
fact that DOD clearances comprise the overwhelming majority of initial
clearance cases that are processed annually. We found that due to the
relative size of DOD's clearance program, DOD's progress towards
meeting IRTPA's timeliness objectives is a significant factor in
reducing the average time required for initial security clearance
processing for the government as a whole. Furthermore, Performance
Accountability Council officials stated that they will begin
conducting one-on-one meetings with individual agencies in September
2010 to enhance communication, assist in implementation planning, and
provide a feedback mechanism for agency stakeholders to communicate
information and needs to the Joint Reform Team.
The Performance Accountability Council is in a position to identify
certain trends and commonalities, such as those challenges related to
resource constraints, manpower limitations, information-sharing,
investigation services quality and cost, and Intelligence Community
specific issues. However, absent complete reporting on the impediments
on meeting timeliness objectives, Congress may not have visibility
over agency compliance and decision makers may not have a complete
picture of the progress made or the impediments to meeting timeliness
objectives. This potential lack of agency transparency and
accountability may impact continued efforts to improve timeliness and
prevent scrutiny over agencies that are not meeting timeliness
objectives.
Executive Agencies Often Grant Reciprocity, Although Challenges Exist
to Measuring and Tracking Reciprocity:
Executive Agency Officials Reported That They Routinely Honor Another
Agency's Security Clearance, but Additional Steps May Be Taken before
Granting Reciprocity:
Officials representing executive branch agencies, including those
within the Intelligence Community, stated that they routinely grant
reciprocity (i.e., accept a background investigation or clearance
determination completed by another authorized investigative or
adjudicative agency). IRTPA generally requires that all security
clearance investigations and determinations be accepted by all
agencies, with limited exceptions when necessary for national security
purposes. We have reported in the past that, according to the
government's plan for addressing problems in the personnel security
clearance process, security clearances are not fully accepted
governmentwide.[Footnote 48] A recent congressional committee report
also suggests that even among the elements of the Intelligence
Community, there are impediments and sometimes lengthy delays in
granting clearances to employees detailed from one agency to another.
[Footnote 49] However, in October 2008, the ODNI issued guidance on
the reciprocity of personnel security clearances.[Footnote 50] The
guidance requires, except in limited circumstances, that all
Intelligence Community elements "accept all in-scope security
clearance or access determinations." Further, OMB guidance[Footnote
51] requires agencies to honor a clearance when: (1) the prior
clearance was not granted on an interim or temporary basis, (2) the
prior clearance investigation is current and in-scope,[Footnote 52]
(3) there is no new derogatory information, and (4) there are no
conditions, deviations, waivers, or unsatisfied additional
requirements (such as polygraphs) if the individual is being
considered for access to highly sensitive programs.[Footnote 53]
Moreover, officials representing two agencies in our review noted that
it is in their best interest to accept a prior clearance because
reciprocity saves time, money, or manpower.
Although officials agreed that they routinely honor another agency's
security clearance, we found that some agencies find it necessary to
take additional steps to address limitations with available
information. Officials representing 18 of the 21 organizations we met
with to discuss reciprocity reported that they must address
limitations, such as insufficient information in the databases or
variances in the scope of investigations, before granting reciprocity.
For example:
* Insufficient information. Although there is no single, integrated
database, security clearance information is shared between OPM, DOD,
and, to some extent, Intelligence Community databases. OPM has taken
steps to ensure certain clearance data necessary for reciprocity is
available to adjudicators. For example, in April 2010, OPM held an
interagency meeting to determine new data fields to include in their
shared database to more fully support reciprocity. However, we found
that the shared information available to adjudicators contains summary-
level detail that may not be complete. As a result, agencies may take
steps to obtain additional information, which creates challenges to
immediately granting reciprocity. For example, to accept a clearance
granted by an intelligence agency, a non-intelligence agency must
access information from the intelligence agencies' Scattered Castles
database. However, according to officials representing the Department
of the Treasury, the Department of Justice, and the Joint Chiefs of
Staff, the Scattered Castles database does not always provide enough
detail to immediately grant reciprocity. According to these officials,
the Scattered Castles summary screen is not detailed enough or does
not include key information, such as the steps taken to mitigate
negative issues. As a result, additional information, such as copies
of the original background investigation, must be sought directly from
intelligence agencies to verify and provide supporting detail to the
information available in Scattered Castles. Similarly, to accept a
clearance granted by a non-intelligence agency, an intelligence agency
must access information from non-intelligence agency databases.
Officials representing Intelligence Community agencies with whom we
spoke noted, for example, that they must contact DOD to determine if
an actual clearance was granted and verify the current status of the
applicant because such detail is not available in DOD's Joint
Personnel Adjudication System. Similarly, officials representing the
Department of Justice told us that while OPM's Central Verification
System shows the existence of conditions, deviations, and waivers,
Department of Justice officials follow up as appropriate with the
agency that granted the clearance.
* Variances in the scope of investigations. We found that the scope of
background investigations varies by level of clearance, which may lead
to duplicative work. For example, a person with a secret-level
clearance may have had one of several types of background
investigations and the scope of the background investigation may vary
depending on the type of clearance sought. Further, officials from two
agencies we spoke with told us that they typically require a certain
type of background investigation and when a subject's clearance is
based on a different type of investigation, they may take additional
steps to fill in the missing gaps to ensure the scope is consistent
with their expectations. Officials representing other agencies
included in our review told us that when the subject's existing
background investigation is different from the required investigation
type, the agency will request a new background investigation. For
example, officials at one agency stated that positions of public trust
sometimes have higher suitability information requirements than
information available from confidential/secret background
investigations. Similarly, officials at another agency stated that
because there are two types of investigations for secret/confidential
clearances based on whether the person is military or contractor or
government civilian, the agency may not be able to accept an
investigation if it is the wrong one for that particular position.
When an entirely new investigation is performed, we found that the
current system may lead to duplicative work, limiting reciprocity. In
a 2008 report to the President, the Joint Reform Team, under the
Performance Accountability Council, proposed revised investigative
standards to, among other things, reduce the types of initial
investigations from 15 to 3.[Footnote 54] While originally planned for
release in December 2010, the Performance Accountability Council
extended plans to issue a new version of the revised Federal
Investigative Standards to calendar year 2011.
In addition to addressing limitations with available information,
agency officials identified broader challenges to granting
reciprocity. Officials representing 14 of the 21 agencies included in
our review of reciprocity reported that challenges, such as the need
to conduct suitability determinations or determine whether a prior
clearance investigation and adjudication meets their quality
expectations, must be addressed before granting reciprocity. For
example:
* Conducting suitability determinations. All federal agencies may be
required to conduct basic suitability determinations to ensure the
applicant's character or conduct is appropriate for the position in
question, but some agencies take additional actions to determine
suitability before they reciprocate a security clearance. For example,
the Department of Justice must take steps to ensure that applicants
for jobs with the Drug Enforcement Administration have not used drugs,
according to agency officials. Similarly, the Intelligence Community
requires a polygraph evaluation, among other things, to determine
suitability for most positions, according to intelligence officials.
We also found that agencies have varying standards for determining
suitability of applicants before reciprocating a security clearance.
For example, Department of Health and Human Services officials said
they will not accept a prior security clearance until it makes a
favorable determination of suitability. Similarly, the Department of
Justice will only accept another agency's clearance and hire the
applicant on a probationary period pending a favorable suitability
determination. As a result of the variances in determining
suitability, OPM, as the Suitability Executive Agent for all executive
agencies, and the Joint Reform Team have issued guidance in line with
Executive Order 13488, which mandates, to the extent practicable and
with certain exceptions, reciprocal recognition of prior favorable
suitability determinations.[Footnote 55] For example, OPM issued a
memorandum for the Heads of Executive Departments and Agencies that
explains how to implement the Executive Order.[Footnote 56]
* Determining whether a prior clearance investigation and adjudication
meets standards. Most agency officials we spoke with stated that since
there is no governmentwide standardized training and certification
process for investigators and adjudicators, a subject's prior
clearance investigation and adjudication may not meet the standards of
the inquiring agency. Although OPM has developed some training,
security clearance investigators and adjudicators are not required to
complete a certain type or number of classes. As a result, the extent
to which investigators and adjudicators receive training varies by
agency. For example, according to ODNI officials, all DOD adjudicators
working at DOD Central Adjudication Facilities must take a basic 2-
week adjudicator course and subsequently the 1-week advanced course
after some time on the job. However, according to officials we spoke
with, the Air Force has an additional requirement for adjudicators to
attend a 3-week training course while the Defense Industrial Security
Clearance Office relies on on-the-job training. Other agencies have
different requirements. For example, the Department of Energy relies
on a mandatory annual security refresher. Consequently, as we have
previously reported, agencies are reluctant to be accountable for
investigations and/or adjudications conducted by other agencies or
organizations.[Footnote 57] To achieve fuller reciprocity, clearance-
granting agencies seek to have confidence in the quality of prior
investigations and adjudications. The annual reports to Congress
indicate that the Performance Accountability Council is taking steps
to make investigations and adjudications more consistent across the
government by standardizing the training of investigators and
adjudicators.[Footnote 58] For example, the reports describe the
development of core courses, as well as a formalized certification for
investigators and adjudicators. According to senior leaders of the
reform effort, these steps will facilitate reciprocal acceptance of
clearance decisions governmentwide.
In the Absence of Consistent Metrics and Reporting Requirements, the
Extent to Which Reciprocity Is Granted Is Unknown:
Although agency officials have stated that reciprocity is regularly
granted, agencies do not have complete records on the extent to which
previously granted security clearance investigations and adjudications
are honored governmentwide. While the Performance Accountability
Council has identified reciprocity as a governmentwide strategic goal,
we found that agencies do not consistently and comprehensively track
when reciprocity is granted, and lack a standard metric for tracking
reciprocity. For example, Department of Justice and Department of
Energy officials said they track both when reciprocity is granted and
reasons for denying a previously granted security clearance, while
Navy and Department of the Treasury officials said they only document
when reciprocity is granted and not when reciprocity is denied. The
Navy checks a box in its electronic database, and the Department of
Energy and the Department of the Treasury manually track when
reciprocity is honored. In contrast, the Army and Air Force do not
track reciprocity at all, according to agency officials. Moreover, it
is unclear the extent to which agencies that do track reciprocity are
reporting the data to oversight agencies, such as ODNI, or sharing
information on reciprocity with each other.[Footnote 59]
OPM and the Performance Accountability Council have developed quality
metrics for reciprocity, but the metrics do not measure the extent to
which reciprocity is being granted. We previously reported that
developing metrics for assessing and regularly monitoring all aspects
of the clearance process could add value in current and future reform
efforts as well as supply better information for greater congressional
oversight.[Footnote 60] While the existing metrics are a positive
step, more is needed to comprehensively capture the extent to which
reciprocity is being granted. For example, OPM created a metric in
early 2009 to track reciprocity, but this metric measures limited
information. OPM's metric measures the number of investigations
requested from OPM that are rejected based on the existence of a
previous investigation and does not track the number of cases in which
reciprocity was or was not successfully honored. The Performance
Accountability Council developed quality metrics, including metrics to
track reciprocity, in response to a March 2010 congressional inquiry.
For example, the Performance Accountability Council proposes as a
metric the average percentage of cases for which prior database checks
are conducted as reported by executive branch agencies. However, this
metric does not account for agencies that checked other databases and
relies on agency self-reporting rather than a systematic method of
data collection. Although the metric helps to create an overall
picture of reciprocity, it does not track which cases were and were
not reciprocated. Similarly, the other metrics included in the
Performance Accountability Council's proposal, such as the number of
duplicate requests for investigations, percentage of applications
submitted electronically, number of electronic applications submitted
by applicant but rejected by OPM as unacceptable due to missing
information or forms, and percentage of fingerprint submissions
determined to be "unclassifiable" by the Federal Bureau of
Investigation, provide useful information, but do not track the extent
to which reciprocity is or is not ultimately honored.
Without comprehensive, standardized metrics to track reciprocity and
consistent documentation of the findings, decision makers will not
have a complete picture of the extent to which reciprocity is granted
or the challenges that agencies face when attempting to honor
previously granted security clearances:
Although There Are No Plans to Develop a Single, Integrated Database,
Steps Have Been Taken to Upgrade Existing Systems and Increase
Information Sharing:
The Executive Branch Has Opted to Leverage Existing Systems in Lieu of
a Single, Integrated Database:
Tasked with establishing a single, integrated database, the executive
branch has opted to focus on leveraging existing systems rather than
establish a new database. IRTPA required that not later than 12 months
after the date of enactment of the act, the Director of the Office of
Personnel Management and the Director of the Office of Management and
Budget establish and commence operating and maintaining a single,
integrated database of security clearance information. This database
was to house information regarding the granting, denial, or revocation
of security clearances or access pertaining to military, civilian, and
contractor personnel, from all authorized investigative and
adjudicative agencies.[Footnote 61] Information from this database
would be used to validate whether a person has or had a clearance,
potentially including such information as the type of investigation
that was conducted and the date of the investigation, thereby
assisting responsible officials in determining whether a new
investigation is required. However, the Performance Accountability
Council is not pursuing a single, integrated database according to our
analysis of a series of recent reports that the Joint Reform Team,
under the Performance Accountability Council, issued between 2008 and
2010.[Footnote 62] For example, according to the Enterprise
Information Technology Strategy, the Performance Accountability
Council has opted to pursue an approach that leverages existing
systems and involves the development of new tools when necessary.
[Footnote 63] According to the Strategic Framework, which was included
with the most recent annual report to Congress, the reform efforts are
focused on leveraging OPM's existing system--the Central Verification
System--to enable access to records on investigations and
adjudications.[Footnote 64] Agency officials from both OPM and ODNI
confirmed that there are no plans to create a new single, integrated
database. Instead, the focus will be on using a single search
capability of existing databases as the means by which they intend to
address the IRTPA requirement. According to an OPM official with whom
we spoke, a single database would not provide any additional
functionality over the single-search capability that they are pursuing.
OPM, DOD, and ODNI officials with whom we spoke explained that
establishing, operating, and maintaining a single, integrated database
is not a viable option due to concerns related to privacy, security,
and data ownership. First, DOD and OPM mentioned privacy concerns,
which involve the unintentional disclosure of personal identifying
information, such as name and Social Security number.[Footnote 65]
Second, merging the different systems into one database raises
security concerns. For example, according to an ODNI official, since
the Intelligence Community's database is classified and separate from
the databases used by non-intelligence agencies, even an aggregation
of unclassified information from its database could lead to
unintentional disclosure of personal identifying information that
could compromise security. Moreover, breaches in the system could also
compromise security. For example, some officials mentioned an enhanced
threat from hackers if there were consolidation of multiple
information technology systems. Finally, according to DOD officials,
there are issues related to data ownership and the copying and
transferring of information between systems that are owned by
different agencies. For example, according to OPM officials, OPM can
not provide information from investigations it did not conduct to
another agency. When investigations are conducted by agencies with
delegated authority, the reports are owned and maintained by the
investigating agency. Requests for these investigative records must be
referred to the owning agency.
Information from Two Primary Databases Can Be Accessed from a Single
Entry Point:
Although there are no plans to create a new governmentwide database,
non-intelligence agencies in our review are sharing information about
personnel who hold or are seeking security clearances through two main
databases that can be accessed through a single entry point. Two
primary databases are used by non-intelligence agencies to store
investigative and adjudicative information and according to the
Performance Accountability Council, they account for decisions on
about 90 percent of all security clearance holders in the federal
government. Data are stored in either OPM's Central Verification
System or DOD's Joint Personnel Adjudication System. The Central
Verification System includes security clearance data for all non-
Intelligence Community, non-DOD executive branch agencies. The Joint
Personnel Adjudication System is a repository for security clearance
information on both DOD civilian and military personnel, as well as
determinations of contractor clearance eligibility and access for the
National Industrial Security Program. Data from the two databases can
be searched and obtained from a single entry point in the Central
Verification System.[Footnote 66]
The Central Verification System was upgraded in spring 2010 and now
provides access to more information than was previously accessible.
Specifically, the upgraded system provides users with a summary of
information on:
* Characteristics of clearances reported to the system. This summary
includes information on active, inactive, and denied clearances, as
well as information on whether there is a condition, deviation, or
waiver.[Footnote 67]
* Characteristics of investigations reported to the system. This
summary includes information on pending, closed, and discontinued
investigations, as well as requests that were deemed unacceptable due
to inadequate or inaccurate information.
* Suitability and fitness. This summary provides information on
adjudication decisions for suitability for federal employees and
fitness for excepted service and contract employee determinations.
[Footnote 68]
* Homeland Security Presidential Directive-12 Personal Identification
Verification Credentials.[Footnote 69] This summary includes
information on the status of credentials issued to the subject
indicating whether the credentials are active, suspended, revoked,
administratively withdrawn, or other.
* Polygraph data. This summary includes information on the type of
polygraph conducted, including Counter-Intelligence or Expanded Scope,
but does not include results from examinations.[Footnote 70]
Intelligence Community Agencies Share Information through a Separate
Database and Are Exploring Alternatives to Expand Information Sharing
with Non-intelligence Agencies:
According to ODNI officials and Intelligence Community Directive 704,
the Intelligence Community agencies share information with one another
through a separate classified database known as Scattered Castles.
Scattered Castles is a repository for records from all intelligence
agencies by which each agency uploads relevant information from
individual agency databases. All personnel who have access to
Sensitive Compartmented Information are listed in Scattered Castles.
This system is not linked to OPM's Central Verification System due to
concerns about protecting classified information. According to ODNI
officials, the system has not been linked to non-intelligence
databases due to the need to protect information on covert personnel.
However, officials representing Intelligence Community agencies stated
that they do enter some information from the Joint Personnel
Adjudication System into Scattered Castles.
Although the Intelligence Community maintains a separate database, we
found that most of the non-intelligence agencies included in our
review had some access to Scattered Castles. For example, five non-
intelligence, non-DOD agencies included in our review had some access
through a Sensitive Compartmented Information Facility located in
their agency.[Footnote 71] All of the military departments, as well as
the Joint Chiefs of Staff, also had some access.[Footnote 72]
Moreover, according to agency officials, DOD adjudicators with the
appropriate clearance and need to know will have access to a Sensitive
Compartmented Information Facility with access to Scattered Castles
when DOD collocates all of its clearance adjudication facilities at
Fort Meade in Maryland as part of the DOD base realignment and closure
process in 2011.
According to Performance Accountability Council officials, the
Performance Accountability Council is participating in an effort to
explore ways to enhance information sharing between the Intelligence
Community agencies and the non-intelligence agencies. A working group
has been established to study alternatives to support a single access
point from which to search clearance information and plans to complete
its review in December 2010. According to an ODNI official,
alternatives currently being considered include a help desk staffed
with employees from the Intelligence Community who would have access
to the Joint Personnel Adjudication System, Central Verification
System, and Scattered Castles and could, upon request, provide the
results of Scattered Castles searches to non-Intelligence Community
agencies.
Conclusions:
Continued personnel security clearance reform relies on strong,
committed executive leadership to sustain the momentum created by the
current reform effort. This type of leadership commitment, in turn,
helps provide oversight and accountability for the improvement
processes. Key to these efforts has been the Performance
Accountability Council, which has provided direction for clearance
reform across the federal government. As a result of the Performance
Accountability Council's actions, federal agencies have made progress
in moving closer to the objectives and requirements outlined in IRTPA.
Under the Performance Accountability Council's leadership, timeliness
data--particularly at DOD--have improved, steps have been taken to
improve information sharing, and there has been focus on honoring
reciprocity of existing clearances. However, while agencies are moving
closer to meeting the objectives and requirements of IRTPA, continued
oversight and accountability for personnel security clearance reform
is still needed. Specifically, executive branch agencies that are
currently not meeting timeliness objectives may need help in
identifying challenges and developing plans with appropriate timelines
to overcome these obstacles. The recent activities undertaken by the
Performance Accountability Council to assist the agencies in
developing plans to implement the reformed approach is a step in the
right direction. Continued reporting required by the Intelligence
Authorization Act for Fiscal Year 2010 will also help ensure that
momentum gained through the reform efforts will continue. However,
without developing more comprehensive metrics to track reciprocity,
executive branch agencies will not have a complete picture of the
degree to which reciprocity is honored.
Recommendations for Executive Action:
To improve the overall personnel security reform efforts across the
federal government, we recommend that the Deputy Director of
Management, Office of Management and Budget, in the capacity as Chair
of the Performance Accountability Council, take the following actions:
* Collaborate with the agencies that are not meeting timeliness
objectives to take the following five actions:
* Identify challenges to timeliness;
* Develop mitigation strategies to enable each agency to comply with
the IRTPA timeliness objectives;
* Set timelines for accomplishing the required actions;
* Monitor agency progress; and:
* Report on these plans and progress in the annual reports to Congress.
* Develop comprehensive metrics to track reciprocity and then report
the findings from the expanded tracking to Congress.
Agency Comments and Our Evaluation:
We provided a draft of our report to OMB, ODNI, and OPM. In response
to this draft, we received oral comments from OMB and written comments
from ODNI and OPM. All three agencies concurred with all of our
recommendations. OMB, ODNI, DOD (through ODNI), and OPM also provided
us with technical comments, which we incorporated in this report, as
appropriate. ODNI and OPM's written comments are reprinted in their
entirety in appendixes II and III, respectively.
In oral comments, OMB generally concurred with both of our
recommendations directed to OMB's Deputy Director of Management in the
capacity as Chair of the Performance Accountability Council. OMB noted
the report's thoroughness and that it highlighted the significant
progress that has been made to improve the timeliness of security
clearance determinations. In response to our recommendations, OMB
described some of the steps that the Performance Accountability
Council was taking to address the recommendations. Regarding our first
recommendation, OMB noted that the Performance Accountability Council
was committed to the timeliness and reciprocity goals of IRTPA and
that it was working with agencies currently not meeting the IRTPA
timeliness goals by taking steps to assist these agencies. Regarding
our second recommendation to develop additional performance measures
to track reciprocity, OMB stated that the Performance Accountability
Council is working to develop these additional metrics.
In written comments, ODNI and OPM both noted the significant overall
progress that has been made in the reform efforts. Specifically, ODNI
noted that DOD, with the majority of clearances, achieved timeliness
goals for adjudications for fiscal year 2010. As we noted in our
report, significant overall progress has been made, largely
attributable to DOD because the department represents a vast majority
of the initial clearances.
In agreeing with and providing comments related to our
recommendations, ODNI described a number of ongoing and future actions
related to our recommendations. For example, ODNI stated that it is
working through the Joint Reform Team to assist executive agencies
that are not meeting IRTPA objectives to develop mitigation strategies
and will report these strategies to Congress in its February 2011
IRTPA Annual Report. Similarly, ODNI stated that it will continue to
work with the Performance Accountability Council's Performance
Management and Measures subcommittee to develop additional measures
for reciprocity, timeliness, and quality, which will also be included
in its annual report to Congress. We are encouraged to see a continued
commitment by executive leaders of the security clearance reform
effort and if implemented in accordance with our recommendations, the
ODNI's actions appear to be a positive step in helping sustain the
momentum of security clearance reform.
In addition to agreeing with our recommendations, OPM provided four
specific comments:
* First, OPM provided comments on the timeliness data provided by the
Performance Accountability Council that we used to frame agency
compliance with IRTPA timeliness objectives. Specifically, OPM stated
in its written comments that some of the Performance Accountability
Council's timeliness data for the second and third quarters of fiscal
year 2010 varies with the data that OPM collects and reports to the
Performance Accountability Council. We acknowledge that in some
instances there are discrepancies between the timeliness data provided
by OPM and the timeliness data that the Performance Accountability
Council provided to us. In some cases, OPM asserts that timeliness
data for investigations is marginally better than reported by the
Performance Accountability Council and in other instances, is
marginally worse. However, none of the discrepancies reported by OPM
affects our findings as it relates to agency compliance with IRTPA
timeliness objectives for the period reported. Agencies we note in
figure 2 continue to either meet or not meet the IRTPA timeliness
goals. As we note in our methodology, for the purposes of this report,
we ultimately selected and relied on data provided by the Performance
Accountability Council's Subcommittee on Performance Management and
Measures. The Performance Accountability Council is responsible for
collecting and reporting agency timeliness data to Congress and
providing oversight to agencies regarding the timeliness of personnel
security clearance processes. The data were provided by the
Performance Accountability Council in August 2010. We conducted a
series of data reliability interviews with knowledgeable officials
with the Performance Accountability Council's subcommittee and
concluded that the data provided were sufficiently reliable for our
purposes.
* Second, OPM also provided comments related to a section of our
report on investigation services quality and cost. Specifically, OPM
noted in its comments that they felt some policies are ambiguous and
that there are customer misperceptions of the sufficiency of OPM
investigations. Further, OPM noted that there is no policy requiring
police and criminal records to be included in its investigative
reports. The ODNI provided a similar technical comment and we made
changes, as appropriate, to reflect this point. However, related to
OPM's comment on agency misperception of the sufficiency of OPM
investigations, we spoke with, and note in our report, several
agencies stated challenges related to deficient investigative reports
provided by OPM. According to these agencies--including DOD, which
constitutes the vast majority of personnel security clearances in the
federal government--the deficiencies in investigative reports slows
their agencies ability to make adjudicative decisions. In fact, as we
note in this report and based on our prior work, documentation was
incomplete for most OPM-provided investigative reports based on
independent review of about 3,500 investigative reports provided to
DOD.[Footnote 73]
* Third, OPM suggested modifications to our discussion of quality
metrics on reciprocity. In its comments, OPM noted that some of the
metrics may have been developed prior to the Performance
Accountability Council's response to a March 2010 congressional
inquiry. We disagree with OPM's characterization of the accuracy of
this section and its suggested modification for two reasons: 1) the
Performance Accountability Council submitted proposed metrics to
congress in May 2010 in response to the congressional inquiry we
already note. Our evidence is derived from this letter to congress for
which the Performance Accountability Council--including OPM--and GAO
are signatories; and 2) OMB, in its capacity as chair of the
Performance Accountability Council, stated in its technical comments
that referring to the proposed metrics as originating from the
Performance Accountability Council was appropriate.
* Finally, OPM noted in its comments pertaining to data ownership,
that OPM can not provide information from investigations it did not
conduct to another agency it did not own. Instead, OPM noted that
requests for these investigative records must be referred to the
owning agency. As a result, we incorporated changes based on this
comment as appropriate.
As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 12 days
from the report date. We will then send copies of this report to the
Senate Appropriations Committee, Senate Committee on Homeland Security
and Governmental Affairs, Senate Select Committee on Intelligence,
Senate Armed Services Committee, House Appropriations Committee, House
Oversight and Government Reform Committee, and House Armed Services
Committee and to members of the Performance Accountability Council,
including the Director of the Office of Management and Budget, Office
of the Director of National Intelligence, Secretary of the Department
of Defense, and the Director of the Office of Personnel Management. In
addition, the report will be available at no charge on the GAO Web
site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-3604 or farrellb@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix IV.
Signed by:
Brenda S. Farrell:
Director, Defense Capabilities and Management:
[End of section]
Appendix I: Scope and Methodology:
Scope:
In conducting our review of the ongoing efforts to reform the
personnel security clearance process, the scope of work included the
Office of Personnel Management (OPM), the Department of Defense (DOD),
and the Office of the Director of National Intelligence (ODNI) as
members of the Performance Accountability Council. Our review included
select members of the Intelligence Community, including the Under
Secretary of Defense for Intelligence, the Central Intelligence
Agency, Defense Intelligence Agency, Federal Bureau of Investigation,
National Geospatial-Intelligence Agency, National Reconnaissance
Office, National Security Agency, and the Department of State. Our
review also included six additional executive branch agencies,
including the Departments of Energy, Health and Human Services,
Homeland Security, Justice, the Treasury, and Veterans Affairs. These
agencies were selected based on the volume of initial personnel
security clearances they process per year for civilians, military, and
industrial personnel, and their use of OPM to conduct background
investigations.
Methodology:
To assess the overall personnel security clearance reform efforts, as
well as each of our objectives, we obtained relevant documentation and
interviewed key federal officials from the following organizations:
* Office of Personnel Management;
* The Department of Defense;
* The Office of the Under Secretary of Defense for Intelligence,
* Department of the Army, Central Clearance Facility,
* Department of the Navy Central Adjudication Facility,
* Department of the Air Force Central Adjudication Facility,
* Defense Industrial Security Clearance Office Central Adjudication
Facility,
* Defense Intelligence Agency,
* National Security Agency,
* Defense Office of Hearings and Appeals,
* Defense Personnel Security Research Center,
* Business Transformation Agency,
* Joint Chiefs of Staff, and:
* Washington Headquarters Services.
* Office of the Director of National Intelligence;
* Department of Energy;
* Department of Health and Human Services;
* Department of Homeland Security;
* Department of Justice;
* Department of the Treasury; and:
* Department of Veterans Affairs.
We conducted a roundtable discussion with members of the Intelligence
Community, including officials from the Office of the Director of
National Intelligence, the Under Secretary of Defense for
Intelligence, the Central Intelligence Agency, Defense Intelligence
Agency, Federal Bureau of Investigation, National Geospatial-
Intelligence Agency, National Reconnaissance Office, National Security
Agency, and the Department of State to discuss broader challenges the
Intelligence Community faces regarding timeliness, information
sharing, and reciprocity.
To assess the extent to which executive branch agencies investigate
and adjudicate initial personnel security clearance applications in a
timely manner, we analyzed the timeliness objectives specified in the
Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) and
reviewed the self-reported timeliness data contained in the
Performance Accountability Council's Security and Suitability Process
Reform Strategic Framework[Footnote 74] provided by the Performance
Accountability Council Subcommittee on Performance Management and
Measures for the first three quarters of fiscal year 2010. The data
provided by the Performance Accountability Council was provided in
August 2010. Further, we obtained and reviewed timeliness data
provided by OPM for agencies that utilize OPM as the investigative
service provider for the first three quarters of fiscal year 2010.
While IRTPA sets timeliness objectives for 90 percent of cases, the
Performance Accountability Council excludes certain cases from its
analysis before calculating and reporting on agency timeliness. For
example, OPM officials stated that cases that are returned to OPM for
additional work, such as work to address missing scope items, are
excluded from timeliness data. Due to the additional investigative
work involved with these cases and the additional time required for
agencies to negotiate the terms of the requests, these cases take
longer to complete. Furthermore, the Performance Accountability
Council excludes certain cases involving industrial personnel. DOD's
Defense Industrial Security Clearance Office adjudicates clearances
for industrial personnel. When the Defense Industrial Security
Clearance Office cannot mitigate issues and has decided that a denial
or revocation is warranted, they submit the cases to the Defense
Office of Hearings and Appeals. Timeliness information on cases
pending with Defense Office of Hearings and Appeals is excluded from
DOD's timeliness data. Moreover, by not including end-to-end
timeliness information on cases that require additional work in the
query for calculating the fastest 90 percent of cases, the Performance
Accountability Council is excluding many of the cases that took the
longest to complete and, therefore, the average for agency timeliness
may be reduced. We assessed the reliability of the data by reviewing
the existing data and interviewing agency officials knowledgeable
about how the data was collected, stored, and reported, as well as the
quality assurance steps that were taken to ensure completeness and
accuracy. We determined these data were sufficiently reliable for
purposes of our audit. Additionally, we supplemented this data
reliability analysis with information obtained through our interviews
with executive branch agencies about their timeliness performance in
fiscal year 2010 to date. These agencies were selected based on the
volume of security clearances processed annually, among other things.
[Footnote 75]
To assess the extent to which executive branch agencies accept
previously granted security clearances and the challenges, if any,
that exist related to reciprocity, we reviewed the requirements
specified in IRTPA and analyzed Executive Orders, OMB memorandums,
ODNI policy guidance and directives, congressional reports, and
individual agency guidance related to reciprocity. We also analyzed
existing and planned metrics developed by the Performance
Accountability Council to track the extent to which reciprocity is
honored. We met with security officials, managers, and adjudicators
from DOD, the Intelligence Community, and a non-probability sample of
additional executive branch agencies. We supplemented this analysis
with information obtained from a roundtable discussion that we
conducted with representatives of Intelligence Community agencies to
examine the challenges these agencies face as it relates to granting
reciprocity. Because the scope of this engagement is limited to
security clearances, we did not analyze the extent to which agencies
reciprocally accept prior suitability investigations and
adjudications. For the purposes of our report reciprocity is an
agency's acceptance of a background investigation or clearance
determination completed by another authorized investigative or
adjudicative agency. We excluded from the scope of our work issues
related to access to facilities, detailed employees, or classified
information.
To assess the extent to which executive branch agencies share
personnel clearance information in a single, integrated database, we
reviewed and analyzed the Joint Reform Team's Enterprise Information
Technology Strategy, the Performance Accountability Council's 2010
Strategic Framework, and the two most recent Joint Reform Team
Security and Suitability Process Reform reports.[Footnote 76]
We interviewed knowledgeable officials within OPM, ODNI, and DOD to
determine what, if any, limitations, barriers, or challenges existed
in creating a single, integrated database. In addition, we received
demonstrations of both OPM and DOD's databases and interviewed
officials to determine how they shared information about personnel who
hold or are seeking security clearances in the absence of a single,
integrated database.
We conducted this performance audit from October 2009 through November
2010 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our objectives.
[End of section]
Appendix II: Comments from the Office of the Director of National
Intelligence:
Director Of National Intelligence:
Washington, Dc 20511:
November 8, 2010:
Gene L. Dodaro:
Acting Comptroller General of the United States:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr, Dodaro:
Thank you for the opportunity to respond to your proposed report
entitled Personnel Security Clearances: Progress Has Been Made to
Improve Timeliness but Continued Oversight is Needed to Sustain
Momentum (GAO-11-65). This report is a fair and thorough assessment of
the Personnel Security Clearance reform effort's progress to date. I
have enclosed my feedback on your report's observations and
recommendations. The Office of the Director of National Intelligence
received input on your report from the Department of Defense, the
Office of Personnel Management, and the Intelligence Community round
table participants.
As GAO noted, significant overall progress has been made to improve
the timeliness of personnel security clearance investigations and
adjudications. The reform effort, led by the Performance
Accountability Council, continues to implement reforms designed to
provide consistent timeliness, improve quality and enable reciprocity
to the fullest extent practical across Executive Branch agencies. We
look forward to working with you in the future as we continue the
reform process.
Sincerely,
Signed by:
James R. Clapper:
Attachment: 1. GAO Draft Report:
cc: Ms. Brenda Farrell:
[End of letter]
Office of the Director of National Intelligence Response:
GAO Draft Report: Personnel Security Clearances: Progress Has Been
Made to Improve Timeliness but Continued Oversight is Needed to
Sustain Momentum (GA0-11-65):
GAO Observation: Significant progress has been made to improve the
timeliness of investigation and adjudication of personnel security
clearances, which was attributable to Department of Defense (DOD)
whose clearances comprise about 90% of government-wide clearances.
Although the majority of clearances are processed within the IRTPA 60-
day objective, individual agency timeliness varies and they continue
to face a number of challenges for meeting timelines objectives,
including personnel limitations, variances among agencies in adopting
information technology caused by resources constraints, and additional
agency-specific requirements that must be met before granting a
security clearance.
ODNI Response: I agree with GAO's observation that significant
timeliness improvements have been made which are due in large part to
implementation of reformed electronic, automated personnel security
processes. It should be further noted that DOD, with the volume
majority of clearances, achieved adjudicative timeliness well under
the 20 day goal for the entire fiscal year which allowed for the
combined Executive Branch investigation/adjudication timeliness to
fall within the 60 days prescribed by IRTPA.
GAO Recommendation 1: GAO recommends that the Performance
Accountability Council collaborate with executive agencies that are
not yet achieving the 60-day timeliness objective to take the
following actions: 1) identify challenges to timeliness, 2) develop
mitigation strategies to enable each agency to comply with IRTPA
timeliness objectives, 3) set timelines for accomplishing the required
actions, 4) monitor agency progress, and 5) report on these plans and
progress in the annual report to Congress.
ODNI Response: Concur. The Security Executive Agent, through Joint
Reform Team (JRT) efforts, collaborates in a variety of ways with all
executive agencies to assist them in improving timeliness,
reciprocity, quality, and other strategic goals outlined in IRTPA.
Agencies submitted timelines for reform in March 2009 via a JRT-
developed plan of actions and milestone (POA&M) template. The JRT
monitors agency progress against their original plans, as well as
challenges to implementation and mitigation strategies if the agency
is behind schedule, through the agency-submitted quarterly updates and
reports progress to the Performance Accountability Council.
In addition, the JRT is conducting agency-focused site visits to
assist agencies by addressing issues GAO identified for action. The
JRT will use these meetings to help agencies further define the
challenges to timeliness and reform implementation and to develop
tailored mitigation plans to achieve reform goals. To provide Congress
additional insight to these activities, the Security Executive Agent
will address agency challenges and mitigation strategies in the
February 2011 IRTPA Annual Report.
GAO Recommendation 2: GAO recommends that the Performance
Accountability Council develop comprehensive, standardized metrics to
track reciprocity and report the findings from the expanded tracking
to Congress.
ODNI Response: The Security Executive Agent, in partnership with the
Performance Accountability Council's Performance Management and
Measures subcommittee, continues to develop additional performance
measures for reciprocity, timeliness, and quality. The Security
Executive Agent will include such measures in its annual report to
Congress.
[End of section]
Appendix III: Comments from the Office of Personnel Management:
United States Office Of Personnel Management:
The Director:
Washington, DC 20415:
November 1, 2010:
Ms. Brenda S. Farrell:
Director, Defense Capabilities and Management:
U.S. Government Accountability Office (GAO):
Washington, DC 20548:
Dear Ms. Farrell:
Thank you for the opportunity to respond to the proposed report
entitled Personnel Security Clearances: Progress has Been Made to
Improve Timeliness but Continued Oversight is Needed
to Sustain Momentum (GAO-11-65). The U.S. Office of Personnel
Management (OPM) is pleased to see that the report recognizes the
progress that has been made in the security clearance process and
agrees with the recommendations that GAO has made at the end of its
report. Our comments to the proposed report are enclosed for your
review and consideration.
Please do not hesitate to contact Merton Miller, Deputy Associate
Director for External Affairs of OPM's Federal Investigative Service
at 202-606-1042 or Tania Shand, Director of OPM's Congressional and
Legislative Affairs at 202-606-1300, if you have any further questions
or wish to discuss our comments.
Sincerely,
Signed by:
John Berry:
Director:
Enclosure:
[End of letter]
Recommended Adjustments to the Draft Statement of Fact, GAO's Review of
Personnel Security Clearance Reform (GAO-11-65):
1. Page 20, Figure 2, revise to include percentage of OPM workload and
correct data: DoD (92.5%)- Second Quarter - replace "45" with "42",
DHS (3.5%), DOE (1.2%) - Second Quarter and Third Quarter - replace
"45" and "44" with "42" and "42" respectively, DOI (0.8%)- Third
Quarter - replace "63" with "65", Treasury (0.2%)- Second Quarter -
replace "56" with "55", HHS (0.3%), VA (0.0%) - Second Quarter and
Third Quarter-replace "78" and "70" with "81" and "63" respectively.
Rationale: Accuracy. Adding workload percentage and correcting
timeliness data will improve accuracy and clarity for the reader. This
timeliness data provided by ODNI is not consistent with OPM's data.
The inconsistency between OPM and ODNI's data is based upon the ODNI's
inability to identify the fastest 90% "Initial" population. ODNI
identifies the fastest 90% of the Top Secret population and then
identifies the fastest 90% of the Secret/Confidential population and
combines the two to determine the average timeliness of the 90% of
that population. ODNI also combines data from the Intelligence
Community that would not be included in OPM's data. Additionally, the
timeliness data reflected in the chart is reflective of investigations
with adjudication actions reported during those periods versus the
investigation "closing" timeliness as reported by OPM and responsive
to the Intelligence Reform and Terrorism Act of 2004. The data for the
non-delegated agencies represented in this chart is accurately
provided by OPM, and accepted by ODNI and approved by OMB on a
quarterly basis. Given that GAO is not questioning the accuracy of the
data provided by OPM, these adjustments to the GAO data are
appropriate.
2. Page 24, first paragraph, revise as follows: "Investigation
services quality and cost." Officials representing agencies that use
OPM as their investigative service provider cited challenges related
to deficient investigative reports as a factor that slows agencies
abilities to make adjudicative decisions-For example, some agencies
noted that OPM investigative reports do not include complete copies of
associated police reports and criminal record checks. We noted in our
prior work that documentation was incomplete for most OPM-provided
investigative reports based on independent review of about 3,500
investigative reports. We also noted in our previous work that
incomplete investigative documentation may lead to increases in the
time it take to complete the clearance process and in the overall
costs of the process. In response, OPM officials stated that ambiguous
policies and customer misunderstanding of the investigative coverage
limitations contribute significantly to perceptions of the sufficiency
of OPM products. For instance, OPM officials state that OPM provides a
summary synopsis of police and criminal record review findings, and
asserts there is no policy requiring inclusion of copies of the
original records while some adjudicative agency personnel disagree. On
the other hand, some investigative coverage requirements are not
satisfied due to coverage limitations as illustrated by the absence of
subject interviews unobtainable because the subject is in a war zone,
or the absence of employment verification when the employing entity
does not permit release of the information. This confusion between
requirements and exceptions and limitations on investigative
collections may unnecessarily delay adjudications and lead agencies
back to OPM for more information. Several agency officials state that
in order to avoid further costs or delays that would result from
working with OPM, they often choose to perform additional steps
internally to obtain missing information, clarify or explain issues
identified in investigative report, or gather evidence for issue
resolution or mitigation.
Rationale: Accuracy. Most of OPM customer agencies were not
interviewed. Of those cited, GAO's quality example illustrates the
clear disconnect between expectations and policy requirements. That
disconnect has its roots in policy ambiguity, which is currently being
addressed by reform efforts to revise investigative standards to
clearly state requirements, to define collateral coverage standards
when primary coverage is unobtainable, and to direct when waivers,
deviations and exceptions are appropriate and acceptable. Having clear
content standards will go a long way to assist the investigative
service provider in fulfilling adjudicative expectations, and the
adjudicator in concluding determinations without concern that they
will be second guessed. Finally, the contrast between intelligence
community circumstances (serving a single, small volume requirement)
with OPM circumstances (serving over 90% of the federal government and
200 plus agencies with multiple contracts) on the treatment of "costs"
is not relevant. Intelligence community entities are all doing very in-
depth investigations to one standard to meet one agencies expectation,
and they have the added ability to insert adjudicator prerogative into
the final determination of sufficiency. OPM is governed by revolving
fund (fee-for-service rules), and must work with contracts to cover a
variety of investigative products, policies and customer expectations.
This is another situation in which having clear standards will do more
to eliminate the need for agencies to revisit investigative products
with OPM, because they will permit OPM to satisfy the expectations the
first time.
3. Page 33, starts three lines from bottom - "Similarly, the other
metrics proposed by the Performance Accountability Council...", delete
the entire bulleted paragraph.
Rationale: Accuracy. The metrics that are identified as "proposed" by
the Joint Reform team were in fact developed by the Management and
Metrics Subcommittee of the Performance Accountability Council some
time ago and have all been regularly included in the quarterly reports
that OPM prepares for OMB and Congress. In fact, the first proposed
metric for "number of duplicate requests for investigation" is
previously mentioned by GAO earlier on page 33 of the draft report
where it states that "OPM created a metric in early 2009 to track
reciprocity..." This is the "duplication" measurement indicated as
"proposed" at the bottom of the page. The other metrics can be found
in the quarterly report under the sections on e-QIP.
4. Page 36, last sentence in first paragraph should be revised to
clarify the reason OPM is unable to provide information from the
investigation provided by another agency.
"For example, OPM is not authorized to provide information it does not
have to another agency. When investigations are conducted by agencies
with delegated authority, the reports are indexed in OPM's SII/CVS but
the actual reports are owned and maintained by the investigating
agency. Requests for these investigative records must be referred to
the owner."
Rationale: Clarity. As written the sentence implied a "willingness"
issue. The revised language makes the point by adding necessary
details.
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov:
Acknowledgments:
In addition to the contact named above, Liz McNally (Assistant
Director); David Moser (Assistant Director); James Ashley; Joseph M.
Capuano; Sara Cradic; Cindy Gilbert; Linda Keefer; James Krustapentus;
Greg Marchand; Richard Powelson; Jillena Roberts; and Amie Steele made
key contributions to this report.
[End of section]
Related GAO Products:
DOD Personnel Security Clearance Reform: Preliminary Observations on
Timeliness and Quality. [hyperlink,
http://www.gao.gov/products/GAO-11-185T]. Washington, D.C.: November
16, 2010.
Privacy: OPM Should Better Monitor Implementation of Privacy-Related
Policies and Procedures for Background Investigations. [hyperlink,
http://www.gao.gov/products/GAO-10-849]. Washington, D.C.: September
7, 2010.
Personnel Security Clearances: An Outcome-Focused Strategy and
Comprehensive Reporting of Timeliness and Quality Would Provide
Greater Visibility over the Clearance Process. [hyperlink,
http://www.gao.gov/products/GAO-10-117T]. Washington, D.C.: October 1,
2009.
Personnel Security Clearances: Progress Has Been Made to Reduce Delays
but Further Actions Are Needed to Enhance Quality and Sustain Reform
Efforts. [hyperlink, http://www.gao.gov/products/GAO-09-684T].
Washington, D.C.: September 15, 2009.
Personnel Security Clearances: An Outcome-Focused Strategy Is Needed
to Guide Implementation of the Reformed Clearance Process. [hyperlink,
http://www.gao.gov/products/GAO-09-488]. Washington, D.C.: May 19,
2009.
DOD Personnel Clearances: Comprehensive Timeliness Reporting, Complete
Clearance Documentation, and Quality Measures Are Needed to Further
Improve the Clearance Process. [hyperlink,
http://www.gao.gov/products/GAO-09-400]. Washington, D.C.: May 19,
2009.
High-Risk Series: An Update. [hyperlink,
http://www.gao.gov/products/GAO-09-271]. Washington, D.C.: January 22,
2009.
DOD Personnel Clearances: Preliminary Observations about Timeliness
and Quality. [hyperlink, http://www.gao.gov/products/GAO-09-261R].
Washington, D.C.: December 19, 2008.
Personnel Security Clearances: Preliminary Observations on Joint
Reform Efforts to Improve the Governmentwide Clearance Eligibility
Process. [hyperlink, http://www.gao.gov/products/GAO-08-1050T].
Washington, D.C.: July 30, 2008.
Personnel Clearances: Questions for the Record Regarding Security
Clearance Reform. [hyperlink,
http://www.gao.gov/products/GAO-08-965R]. Washington, D.C.: July 14,
2008.
Personnel Clearances: Key Factors for Reforming the Security Clearance
Process. [hyperlink, http://www.gao.gov/products/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/products/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/products/GAO-08-580R]. Washington D.C.: March 25,
2008.
DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts
to Improve Clearance Processes for Industry Personnel. [hyperlink,
http://www.gao.gov/products/GAO-08-470T]. Washington, D.C.: February
12, 2008.
Personnel Clearances: Key Factors to Consider in Efforts to Reform
Security Clearance Processes. [hyperlink,
http://www.gao.gov/products/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/products/GAO-08-350]. Washington, D.C.: February
13, 2008.
DOD Personnel Clearances: Delays and Inadequate Documentation Found
for Industry Personnel. [hyperlink,
http://www.gao.gov/products/GAO-07-842T]. Washington, D.C.: May 17,
2007.
High Risk Series: An Update. [hyperlink,
http://www.gao.gov/products/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/products/GAO-06-1070]. Washington, D.C.: September
28, 2006.
DOD Personnel Clearances: Questions and Answers for the Record
Following the Second in a Series of Hearings on Fixing the Security
Clearance Process. [hyperlink,
http://www.gao.gov/products/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/products/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/products/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/products/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/products/GAO-06-233T]. Washington, D.C.: November
9, 2005.
DOD Personnel Clearances: Some Progress Has Been Made but Hurdles
Remain to Overcome the Challenges That Led to GAO's High-Risk
Designation. [hyperlink, http://www.gao.gov/products/GAO-05-842T].
Washington, D.C.: June 28, 2005.
High-Risk Series: An Update. [hyperlink,
http://www.gao.gov/products/GAO-05-207]. Washington, D.C.: January
2005.
[End of section]
Footnotes:
[1] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-05-207] (Washington, D.C.: January
2005).
[2] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-07-310] (Washington, D.C.: January
2007); and High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January
2009).
[3] GAO, DOD Personnel Clearances: Comprehensive Timeliness Reporting,
Complete Clearance Documentation and Quality Measures Are Needed to
Further Improve the Clearance Process, [hyperlink,
http://www.gao.gov/products/GAO-09-400] (Washington, D.C.: May 19,
2009).
[4] Pub. L. No. 108-458, §3001 (2004) (codified at 50 U.S.C. 435b).
While IRTPA was a far-reaching act with many broad implications, our
references to it throughout this report pertain solely to section
3001, unless otherwise specified.
[5] This team also now includes representatives of the Office of
Management and Budget and Office of Personnel Management.
[6] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January
2009).
[7] H.R. Rep. No. 110-916 (2008).
[8] In the last 3 years, GAO has also testified on security clearance
reform before (1) the Subcommittee on Oversight of Government
Management, the Federal Workforce, and the District of Columbia of the
Senate Committee on Homeland Security and Governmental Affairs, (2)
the Subcommittee on Government Management, Organization, and
Procurement, House Committee on Oversight and Government Reform, and
(3) the Subcommittee on Readiness, House Committee on Armed Services.
[9] Pub. L. No. 111-259, § 367 (2010).
[10] [hyperlink, http://www.gao.gov/products/GAO-09-400]; and
Personnel Security Clearances: An Outcome-Focused Strategy Is Needed
to Guide Implementation of the Reformed Clearance Process, [hyperlink,
http://www.gao.gov/products/GAO-09-488] (Washington, D.C.: May 19,
2009).
[11] We met with officials from the Central Intelligence Agency,
Defense Intelligence Agency, Federal Bureau of Investigation, National
Geospatial-Intelligence Agency, National Reconnaissance Office,
National Security Agency, and the Department of State.
[12] We met with officials from the Departments of Energy, Health and
Human Services, Homeland Security, Justice, the Treasury, and Veterans
Affairs.
[13] We selected agencies based on their ability to meet a combination
of one or more of the following criteria: (1) utilizes Office of
Personnel Management to conduct security clearance investigations, (2)
conducts an average of 5,000 cases per year, (3) is an Intelligence
Community agency, or (4) is a member of the Performance Accountability
Council. Because this is a non-probability sample, our findings do not
generalize to the agencies that we did not include in our review.
[14] Department of Defense: Air Force, Army, Navy, Defense Industrial
Security Clearance Office, Defense Intelligence Agency, Defense Office
of Hearings and Appeals, Washington Headquarters Services, Joint
Chiefs of Staff Central Adjudication Facilities, Business
Transformation Agency, Defense Personnel Security Research Center,
Office of the Under Secretary of Defense for Intelligence, and the
National Security Agency; Intelligence Community: National Geospatial-
Intelligence Agency, National Reconnaissance Office, Central
Intelligence Agency, Federal Bureau of Investigation, Department of
State Bureau of Intelligence and Research, and Office of the Director
of National Intelligence; and additional executive branch agencies:
Health and Human Services, Department of Energy, Department of
Homeland Security, Department of the Treasury, Department of Justice,
Office of Personnel Management, and Department of Veterans Affairs.
[15] Performance Accountability Council, Security and Suitability
Process Reform Strategic Framework (Washington, D.C.: February 2010).
This report was created under the Performance Accountability Council
by the Joint Reform Team.
[16] Performance Accountability Council, Security and Suitability
Process Reform Strategic Framework (Washington, D.C.: February 2010).
[17] Our analysis of timeliness data does not include the following
elements of the agencies in our review: Department of Homeland
Security: Homeland Security Headquarters, Immigration and Customs
Enforcement, U.S. Secret Service, U.S. Customs and Border Protection,
select positions in the U.S. Coast Guard; Department of Justice:
Bureau of Alcohol, Tobacco, Firearms and Explosives; and Department of
the Treasury: Bureau of the Public Debt, Bureau of Engraving and
Printing.
[18] These databases included DOD's Joint Personnel Adjudication
System, OPM's Central Verification System, and the Intelligence
Community's Scattered Castles.
[19] Pub. L. No. 108-458, § 3001 (2004) (codified at 50 U.S.C. §
435b). According to IRTPA, this period shall include a period of not
longer than 40 days to complete the investigative phases of the
clearance review and a period of not longer than 20 days to complete
the adjudicative phase of the clearance review. These measures apply
to initial personnel security clearances (i.e., cases in which
individuals who enter positions in government or industry that require
a clearance do not have a clearance or have not been granted
reciprocity).
[20] Performance Accountability Council, Security and Suitability
Process Reform Strategic Framework (Washington, D.C.: February 2010).
[21] IRTPA's new timeliness objectives became effective as of December
17, 2009, midway through the first quarter of the fiscal year. This
analysis is based on the methodology used by the Performance
Accountability Council that counts the fastest end-to-end cases based
only on completed cases adjudicated by the respective agencies in the
specified quarter of the fiscal year.
[22] The Intelligence Authorization Act for Fiscal Year 2010 extended
this reporting requirement beyond 2011. Pub. L. No. 111-259, § 367
(2010).
[23] Pub. L. No. 108-458, § 3001(d) (2004) (codified at 50 U.S.C.
435b(d)).
[24] ODNI, Intelligence Community Policy Guidance 704.4, Reciprocity
of Personnel Security Clearance and Access Determinations (Oct. 2,
2008).
[25] Office of Management and Budget, Memorandum for Deputies of
Executive Departments and Agencies: Reciprocal Recognition of Existing
Personnel Security Clearance (Dec. 12, 2005).
[26] GAO, Personnel Clearances: Key Factors to Consider in Efforts to
Reform Security Clearance Processes, [hyperlink,
http://www.gao.gov/products/GAO-08-352T] (Washington, D.C.: Feb. 27,
2008).
[27] Pub. L. No. 108-458, §3001(e) (2004) (codified at 50 U.S.C. §
435b(e)).
[28] Performance Accountability Council, Suitability and Security
Process Reform: Strategic Framework (Washington, D.C., February 2010).
[29] Sensitive Compartmented Information is classified intelligence
information concerning or derived from intelligence sources, methods,
or analytical processes that is required to be protected within formal
access control systems established and overseen by the Director of
National Intelligence. A Special Access Program is a program
established for a specific class of classified information that
imposes safeguarding and access requirements that exceed those
normally required for information at the same classification level.
[30] According to the Performance Accountability Council's Strategic
Framework, the federal government conducts almost 900,000 national
security investigations a year.
[31] If a clearance holder has a long-term need to access classified
information, the clearance must be renewed: top secret, 5 years;
secret, 10 years; and confidential, 15 years.
[32] Determinations of suitability for government employment in
positions in the competitive service and for career appointment in the
Senior Executive Service include consideration of aspects of an
individual's character or conduct that may have an impact on the
integrity or efficiency of their service. Exec. Order No. 13467,
Reforming Processes Related to Suitability for Government Employment,
Fitness for Contractor Employees, and Eligibility for Access to
Classified National Security Information, at 1.2(I) (June 30, 2008)
(citing 5 C.F.R. Part 731).
[33] [hyperlink, http://www.gao.gov/products/GAO-05-207]; [hyperlink,
http://www.gao.gov/products/GAO-07-310]; and [hyperlink,
http://www.gao.gov/products/GAO-09-271].
[34] Exec. Order No. 13381, Strengthening Processes Relating to
Determining Eligibility for Access to Classified National Security
Information (June 27, 2005). This order was revoked by Exec. Order No.
13467, Reforming Processes Related to Suitability for Government
Employment, Fitness for Contractor Employees, and Eligibility for
Access to Classified National Security Information (June 30, 2008).
[35] Exec. Order No. 13467, Reforming Processes Related to Suitability
for Government Employment, Fitness for Contractor Employees, and
Eligibility for Access to Classified National Security Information
(June 30, 2008).
[36] Pub. L. No. 108-458, §3001 (2004). IRTPA timeliness objectives
apply only to initial personnel security clearances. Initial
clearances involves cases in which individuals who enter positions in
government or industry that require a clearance do not have a
clearance or have not been granted reciprocity to honor a previously
granted clearance.
[37] Effective December 17, 2009, this IRTPA objective replaced the
IRTPA requirement that determinations on 80 percent of initial
clearances be made within an average of 120 days or less (90 days for
investigations and 30 days for adjudications).
[38] Performance Accountability Council, Security and Suitability
Process Reform Strategic Framework (Washington, D.C.: February 2010).
[39] This analysis is based on the methodology used by the Performance
Accountability Council that counts the fastest end-to-end cases based
only on completed cases adjudicated by the respective agencies in the
specified quarter of the fiscal year.
[40] According to DOD officials, DOD's system for tracking and
reporting security clearance case information does not differentiate
between initial secret/confidential clearances and renewal secret/
confidential clearances. Therefore, the Performance Accountability
Council timeliness reports on initial clearances include DOD secret/
confidential renewal cases.
[41] Under Exec. Order No. 13467, Reforming Processes Related to
Suitability for Government Employment, Fitness for Contractor
Employees, and Eligibility for Access to Classified National Security
Information, sec. 2.3(c)(iv)) (June 30, 2008), the Director of
National Intelligence, as the Security Executive Agent, has the
authority to designate agencies to conduct investigations. Agencies
are required to use OPM as the investigative service provider for
initial clearances unless the Director of National Intelligence has
provided them with delegated authority to conduct their own
investigations.
[42] Homeland Security Presidential Directive-12 (HSPD-12), Policies
for a Common Identification Standard for Federal Employees and
Contractors (August. 27, 2004).
[43] Electronic delivery systems enable investigative service
providers to electronically transmit completed investigative files to
adjudicative agencies. Electronic adjudication capabilities determine
if the subject meets the adjudicative guidelines based on
investigative reports. These capabilities enable adjudicative
determinations for cases that do not contain issues that may affect an
individual's eligibility to access classified information or systems
to be made. Currently, electronic adjudication systems are only
approved to adjudicate secret or confidential clearance cases.
[44] Case management workflow tools, such as DOD's Case Adjudication
Tracking System, are used by adjudicators to document the completeness
of investigative files, manage the adjudication process, and document
decisions made and actions taken regarding a case. The Clearance
Adjudication Tracking System provides both electronic delivery and
electronic adjudication capabilities.
[45] These DOD component agencies include the Joint Chiefs of Staff,
Army, Navy, and the Defense Office of Hearings and Appeals. The
Defense Intelligence Agency, who adjudicates certain cases for the
Joint Chiefs of Staff and Washington Headquarters Services, provided
similar comments.
[46] [hyperlink, http://www.gao.gov/products/GAO-09-400].
[47] [hyperlink, http://www.gao.gov/products/GAO-09-400].
[48] GAO, DOD Personnel Clearances: Government Plan Addresses Some
Longstanding Problems with DOD's Program, But Concerns Remain,
[hyperlink, http://www.gao.gov/products/GAO-06-233T] (Washington,
D.C.: Nov. 9, 2005).
[49] H.R. Rep. No. 110-916 (2008).
[50] ODNI, Intelligence Community Policy Guidance 704.4, Reciprocity
of Personnel Security Clearance and Access Determinations (Oct. 2,
2008).
[51] Office of Management and Budget, Memorandum for Deputies of
Executive Departments and Agencies: Reciprocal Recognition of Existing
Personnel Security Clearances (Dec. 12, 2005); Office of Management
and Budget, Memorandum for Deputies of Executive Departments and
Agencies: Reciprocal Recognition of Existing Personnel Security
Clearances (July 17, 2006).
[52] Intelligence Community Standard 2008-700-1 defines scope as the
time period to be covered and the sources of information to be
contacted during the prescribed course of a personnel security
investigation. OMB considers significant scope deficiencies to be
deviations. Therefore, agencies are not required to honor a previous
clearance that is not "in-scope". Furthermore, challenges identified
in this section of the report may not apply to "out-of-scope"
clearances.
[53] According to Intelligence Community Policy Guidance Number 704.4,
conditions, deviations, and waivers are defined as: (1) condition:
access eligibility granted or continued with the provision that
additional security measures shall be required; (2) deviation: access
eligibility granted or continued despite either a significant gap in
coverage or scope in the investigation or an out-of-date
investigation; (3) waiver: access eligibility granted or continued
despite the presence of substantial issue information that would
normally preclude access.
[54] Joint Security and Suitability Reform Team, Security and
Suitability Process Reform (December 2008).
[55] Exec. Order No. 13488, Granting Reciprocity on Excepted Service
and Federal Contractor Employee Fitness and Reinvestigating
Individuals in Positions of Public Trust (Jan. 16, 2009).
[56] Memorandum from John Berry, Director, Office of Personnel
Management, to Heads of Executive Departments and Agencies, Guidance
on Implementing Executive Order 13488: Granting Reciprocity on
Excepted Service and Federal Contractor Employee Fitness and
Reinvestigating Individuals in Positions of Public Trust (Sept. 24,
2009).
[57] [hyperlink, http://www.gao.gov/products/GAO-08-352T].
[58] [hyperlink, http://www.gao.gov/products/GAO-09-488].
[59] Executive Order 13467 established the Director of the National
Intelligence as the Security Executive Agent and requires the ODNI to
ensure reciprocal recognition of eligibility for access to classified
information among the agencies.
[60] [hyperlink, http://www.gao.gov/products/GAO-08-352T].
[61] Pub. L. No. 108-458, § 3001(e) (2004).
[62] Joint Security and Suitability Reform Team, Security and
Suitability Process Reform (Washington, D.C.: April 2008 and updated
December 2008); Joint Security and Suitability Reform Team, Enterprise
Information Technology Strategy (Washington, D.C.: Mar. 17, 2009); and
Performance Accountability Council, Security and Suitability Process
Reform: Strategic Framework (Washington, D.C., February 2010).
[63] Joint Security and Suitability Reform Team, Enterprise
Information Technology Strategy (Washington, D.C., Mar. 17, 2009).
[64] Performance Accountability Council, Security and Suitability
Process Reform: Strategic Framework (Washington, D.C., February 2010).
[65] [5] According to OMB Memorandum M-07-16, dated May 22, 2007,
"Personally Identifiable Information" refers to information which can
be used to distinguish or trace an individual's identity (e.g., name,
social security number, biometric records), alone or when combined
with other personal or identifying information that is linked or
linkable to a specific individual (e.g., date and place of birth,
mother's maiden name).
[66] DOD data available through this single entry point includes name,
Social Security number, date and type of investigation, and clearance
eligibility.
[67] According to Intelligence Community Policy Guidance Number 704.4,
conditions, deviations, and waivers are defined as (1) condition:
access eligibility granted or continued with the provision that
additional security measures shall be required; (2) deviation: access
eligibility granted or continued despite either a significant gap in
coverage or scope in the investigation or an out-of-date
investigation; (3) waiver: access eligibility granted or continued
despite the presence of substantial issue information that would
normally preclude access.
[68] OPM guidance for implementing Executive Order 13488 defines
Excepted Service positions as those positions: (1) not in the
competitive service; (2) not in the career senior executive service;
(3) and not in the Intelligence Community unless covered by OPM
appointing authorities.
[69] The Homeland Security Presidential Directive-12, issued on August
27, 2004, requires that United States government agencies collaborate
to develop a federal standard for secure and reliable forms of
identification for all U.S. government employees and contractors
needing regular physical access to federal facilities.
[70] According to ODNI and DOD officials, Counter-Intelligence
polygraphs address issues such as foreign contacts and media
disclosure. Expanded Scope polygraphs address questions not reported
on the application forms about criminal activity, computer misuse, and
falsification of applications.
[71] The non-intelligence, non-DOD agencies include the Department of
Energy, Department of Justice, Department of the Treasury, Department
of Homeland Security, Department of Health and Human Services, and
Department of Veterans Affairs.
[72] Army Central Adjudication Facility officials said that their
access was based on a case by case basis.
[73] [hyperlink, http://www.gao.gov/products/GAO-09-400].
[74] Performance Accountability Council, Security and Suitability
Process Reform Strategic Framework (Washington, D.C.: February 2010).
[75] We met with officials from the Departments of Energy, Health and
Human Services, Homeland Security, Justice, the Treasury, and Veterans
Affairs. We selected agencies based on their ability to meet a
combination of one or more of the following criteria: (1) utilizes OPM
to conduct security clearance investigations, (2) conducts an average
of 5,000 cases per year, (3) is an Intelligence Community agency, or
(4) is a member of the Performance Accountability Council. Because
this is a non-probability sample, our findings do not generalize to
the agencies that we did not include in our review.
[76] Joint Security and Suitability Reform Team, Security and
Suitability Process Reform (Washington, D.C.: April 2008 and updated
December 2008); Joint Security and Suitability Reform Team, Enterprise
Information Technology Strategy (Washington, D.C.: Mar. 17, 2009); and
Performance Accountability Council, Security and Suitability Process
Reform: Strategic Framework (Washington, D.C., February 2010).
[End of section]
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