DOD Personnel Clearances
Questions for the Record Related to the Quality and Timeliness of Clearances
Gao ID: GAO-08-580R March 25, 2008
On February 13, 2008, Mr. Jack Edwards--an Acting Director in our Defense Capabilities and Management team--testified before the subcommittee at a hearing on the Department of Defense (DOD) security clearance processes. This report responds to a Congressional request for additional information on that subject. Specifically, GAO was asked the following: (1) In the report that GAO issued today to this committee and your testimony statement, you discussed a need for more emphasis on quality in clearance products and processes. What have agencies been using as quality measures, and are they sufficient? (2) Do you believe that DOD, Office of Management and Budget (OMB), and Office of Personnel Management (OPM) have made the necessary commitment to improve the security clearance process? What steps need to be taken to ensure that on-going initiatives continue past this Administration? (3) The Intel Reform Act requires that timeliness statistics be reported to Congress. Do the timeliness statistics provide a full picture of how quickly clearances are being issued? If there are additional statistics that would add to the Congress's oversight of clearance timeliness, what types of factors should be considered in identifying additional metrics?
Through our reports and testimonies, we have emphasized a need to build more quality and quality monitoring into the clearances process. As we have reported, since 1999 government agencies have relied on a measure of quality--the percentage of investigative reports returned by requesting agencies to the investigating agency because of incompleteness--and this measure is insufficient. We find this measure to be problematic because the number of investigations returned for rework is not by itself a valid indicator of the quality of investigative work. One reason for this is that according to adjudication officials, they were reluctant to return incomplete investigations in anticipation of further delays. Additionally, this metric pertains only to the investigation phase of the clearance process, and there are no metrics for the other five phases of the investigative process (the clearance process has six phases: the requirements setting, application-submission, investigation, adjudication, appeal, and clearance updating). As noted in our February 13, 2008 report, we are encouraged by some department specific and governmentwide efforts that have improved DOD's personnel security clearance program. Examples of improvements to the process include (1) DOD's ability to electronically submit a clearance applicant's form authorizing the release of medical information and (2) a governmentwide effort that has resulted in the increased use of the Office of Personnel Management's (OPM) Electronic Questionnaires for Investigations Processing. Nevertheless, as we noted in our February 13, 2008 statement, we have identified a number of challenges in our past work that will require long-term commitment from this and subsequent administrations to further improve the security clearance process. Current and future efforts to reform personnel security clearance processes should consider, among other things, the following four key factors: (1) determining whether clearances are required for a specific position, (2) incorporating quality control steps throughout the clearance processes, (3) establishing metrics for assessing all aspects of clearance processes, and (4) providing Congress with the long-term funding requirements of security clearance reform. The timeliness statistics that OMB and OPM have provided to Congress may not convey the full magnitude of the time required to complete clearance investigations and adjudications. In May 2007, we reported the following five concerns with the transparency of the government's timeliness statistics: (1) limited information on reinvestigations for clearance updating, (2) not counting the total number of days to finish the application-submission phase, (3) shifting some investigation-related days to the adjudication phase or not counting them, (4) not counting the total number of days to complete closed pending cases, and (5) not counting the total number of days to complete investigations sent back for rework. Our preliminary observations of OMB's February 2008 Report of the Security Clearance Oversight Group and recent OPM congressional testimony indicate that there may be continuing problems in these areas.
GAO-08-580R, DOD Personnel Clearances: Questions for the Record Related to the Quality and Timeliness of Clearances
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March 25, 2008:
The Honorable Solomon P. Ortiz:
Chairman:
The Honorable J. Randy Forbes:
Ranking Member:
Subcommittee on Readiness:
Committee on Armed Forces:
House of Representatives:
Subject: DOD Personnel Clearances: Questions for the Record Related to
the Quality and Timeliness of Clearances:
On February 13, 2008, Mr. Jack Edwards--an Acting Director in our
Defense Capabilities and Management team--testified before your
subcommittee at a hearing on the Department of Defense (DOD) security
clearance processes.[Footnote 1] This report responds to your request
for additional information on that subject. Your questions, and our
responses, follow.
1. In the report that GAO issued today to this committee and your
testimony statement, you discussed a need for more emphasis on quality
in clearance products and processes. What have agencies been using as
quality measures, and are they sufficient?
Through our reports and testimonies, we have emphasized a need to build
more quality and quality monitoring into the clearances process. As we
have reported, since 1999 government agencies have relied on a measure
of quality--the percentage of investigative reports returned by
requesting agencies to the investigating agency because of
incompleteness--and this measure is insufficient. We find this measure
to be problematic because the number of investigations returned for
rework is not by itself a valid indicator of the quality of
investigative work. One reason for this is that according to
adjudication officials, they were reluctant to return incomplete
investigations in anticipation of further delays.[Footnote 2]
Additionally, this metric pertains only to the investigation phase of
the clearance process, and there are no metrics for the other five
phases of the investigative process (the clearance process has six
phases: the requirements setting, application-submission,
investigation, adjudication, appeal, and clearance updating).
2. Do you believe that DOD, OMB, and OPM have made the necessary
commitment to improve the security clearance process? What steps need
to be taken to ensure that on-going initiatives continue past this
Administration?
As noted in our February 13, 2008 report,[Footnote 3] we are encouraged
by some department-specific and governmentwide efforts that have
improved DOD's personnel security clearance program. Examples of
improvements to the process include (1) DOD's ability to electronically
submit a clearance applicant's form authorizing the release of medical
information and (2) a governmentwide effort that has resulted in the
increased use of the Office of Personnel Management's (OPM) Electronic
Questionnaires for Investigations Processing.
In addition, as we have previously reported, we have been encouraged by
the commitment that the Office of Management and Budget (OMB) and OPM
have demonstrated in the development of a governmentwide plan to
address clearance-related problems.[Footnote 4] The OMB Deputy Director
met with us to discuss OMB's general strategy for addressing the
problems that led to our high-risk designation for DOD's clearance
program. Demonstrating strong management commitment and top leadership
support to address a known risk is one of the requirements for us to
remove DOD's clearance program from our high-risk list.
Nevertheless, as we noted in our February 13, 2008 statement, we have
identified a number of challenges in our past work that will require
long-term commitment from this and subsequent administrations to
further improve the security clearance process. Specifically, in our
statement we emphasized the need for initiative in five areas: (1)
improvement in projecting future industry investigation needs, (2)
eliminating delays in the clearance processes, (3) supplementing the
limited information on quality of clearance products and procedures,
(4) increasing the amount of clearance-related funding information
available to Congress to improve oversight, and (5) developing and
implementing a department-specific plan to address clearance
problems.[Footnote 5]
In another recent testimony,[Footnote 6] we emphasized that current and
future efforts to reform personnel security clearance processes should
consider, among other things, the following four key factors: (1)
determining whether clearances are required for a specific position,
(2) incorporating quality control steps throughout the clearance
processes, (3) establishing metrics for assessing all aspects of
clearance processes, and (4) providing Congress with the long-term
funding requirements of security clearance reform.
3. The Intel Reform Act requires that timeliness statistics be reported
to Congress. Do the timeliness statistics provide a full picture of how
quickly clearances are being issued? If there are additional statistics
that would add to the Congress's oversight of clearance timeliness,
what types of factors should be considered in identifying additional
metrics?
The timeliness statistics that OMB and OPM have provided to Congress
may not convey the full magnitude of the time required to complete
clearance investigations and adjudications. In May 2007, we reported
the following five concerns with the transparency of the government's
timeliness statistics: (1) limited information on reinvestigations for
clearance updating, (2) not counting the total number of days to finish
the application-submission phase, (3) shifting some investigation-
related days to the adjudication phase or not counting them, (4) not
counting the total number of days to complete closed pending cases, and
(5) not counting the total number of days to complete investigations
sent back for rework.[Footnote 7] Our preliminary observations of OMB's
February 2008 Report of the Security Clearance Oversight Group and
recent OPM congressional testimony indicate that there may be
continuing problems in these areas.
* Limited information on reinvestigations for clearance updating: In
previous OMB reports and OPM congressional testimony, the government
provided limited information on the time to complete reinvestigations.
However, OMB included in its 2008 Report of the Security Clearance
Oversight Group information on the timeliness of reinvestigations.
* Not counting the total number of days to finish the application-
submission phase: Our preliminary observations of OMB's February 2008
report raise concerns that some activities occurring in the initial
part of the application-submission phase may not be included when
counting the time to complete the application-submission phase. For
example, OMB's February 2008 report noted that investigation timeliness
was "calculated from receipt of the full request for investigation;"
however, some activities may be excluded in timeliness measurements
depending on how OMB interprets the "full request for investigation."
* Shifting some investigation-related days to the adjudication phase or
not counting them: In our September 2006 report, we raised concerns
about how the time to complete the adjudication phase was measured
because OMB included mailing time in reporting the timeliness of the
adjudication phase.[Footnote 8] This practice continues as noted in
OMB's February 2008 report to Congress: timeliness statistics for
adjudications "include... up to 15 days in mail and handling between
OPM and the adjudicating agency." Including time to mail and handle
investigative reports from OPM to adjudicating agencies shifts a
portion of the time to complete the investigation to the adjudication
phase.
* Not counting the total number of days to complete closed pending
cases: OPM may be combining two kinds of investigations, which may
overstate the timeliness of completed investigations. In her February
13, 2008, congressional testimony statement, the Associate Director in
charge of OPM's investigations unit did not indicate whether the
investigation timeliness statistics presented in her statement included
closed pending investigations in the calculation of the average times
to complete all investigations. Closed pending investigations are
investigative reports sent to adjudication facilities without one or
more types of source data required by the federal investigative
standards. In our February 2004 report, we noted that closed pending
cases should continue to be tracked separately in the investigations
phase of the clearance process because a closed pending investigation
may be reopened when the missing data are supplied. The time
measurement of a closed pending case is suspended for an undetermined
amount of time, which is not accounted for if the pending cases are
reopened later and included in the timeliness calculations of fully
completed investigations.
Not counting the total number of days to complete investigations sent
back for rework: In 2006, we reported that in instances when
investigative reports are returned to OPM to address investigative
insufficiencies, OPM's procedure has been to replace the investigative
time recorded for providing the initial report to the adjudication
agency with the investigation time to rework the report to address the
insufficiencies. Reworking the investigative report could take less
time than the earlier effort to complete the initial investigative
report. While reworking cases occurs approximately in 1 to 2 percent of
investigative reports, replacing the initial investigative time with
the time to complete the reworked investigations as the total number of
days to complete investigations does not provide a full picture of how
quickly clearances are being issued. OMB's February 2008 report does
not clarify its timeliness statistics to show how or if it is
addressing this issue.
Finally, during the hearing, each of the panel members was asked to
respond for the record to a series of questions about a database that
may record statistics on the reciprocity of clearances. Specifically,
we were asked which government agency is maintaining a database that
records instances of nonreciprocity, what agencies have the most cases
of nonreciprocity, how many waivers were granted in the last year, and
why such information about reciprocity was not provided in OMB's annual
report to Congress. We are not aware of a database maintained by any
government agency that records information on reciprocity.
If you or other members of the subcommittee have any additional
questions about DOD's personnel security clearance processes, please
contact Brenda S. Farrell at (202) 512-3604 or farrellb@gao.gov. In
addition, contact points for our Offices of Congressional Relations and
Public Affairs may be found on the last page of this correspondence.
GAO staff members who made major contributions to this correspondence
are listed in the enclosure.
Signed by:
Brenda S. Farrell:
Director, Defense Capabilities and Management:
Enclosure:
[End of section]
Enclosure I: GAO Contact and Staff Acknowledgments:
GAO Contact: Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov:
Acknowledgments: In addition to the contact above, Jack E. Edwards,
Acting Director; David E. Moser, Assistant Director; Grace Coleman;
James P. Klein; Ron La Due Lake; Oscar Mardis; and Karen Thornton, made
key contributions to this correspondence.
[End of section]
Footnotes:
[1] GAO, DOD Personnel Clearances: DOD Faces Multiple Challenges in Its
Efforts to Improve Clearance Processes for Industry Personnel, GAO-08-
470T (Washington, D.C.: Feb. 13, 2008).
[2] For example, GAO, DOD Personnel Clearances: Additional OMB Actions
Are Needed to Improve the Security Clearance Process, GAO-06-1070
(Washington, D.C.: Sept. 28, 2006); DOD Personnel Clearances:
Government Plan Addresses Some Long-standing Problems with DOD's
Program, But Concerns Remain, GAO-06-233T (Washington, D.C.: Nov. 9,
2005); and DOD Personnel: Inadequate Personnel Security Investigations
Pose National Security Risks, GAO/NSIAD-00-12 (Washington, D.C.: Oct.
27, 1999).
[3] GAO, DOD Personnel Clearances: Improved Annual Reporting Would
Enable More Informed Congressional Oversight, GAO-08-350 (Washington,
D.C.: Feb. 13, 2008).
[4] GAO, DOD Personnel Clearances: Questions and Answers for the Record
Following the Second in a Series of Hearings on Fixing the Security
Clearance Process, GAO-06-693R (Washington, D.C.: June 14, 2006).
[5] GAO-08-470T.
[6] GAO, Personnel Clearances: Key Factors to Consider in Efforts to
Reform Security Clearance Processes, GAO-08-352T (Washington, D.C.:
Feb. 27, 2008).
[7] GAO, DOD Personnel Clearances: Delays and Inadequate Documentation
Found for Industry Personnel, GAO-07-842T (Washington, D.C.: May 17,
2007).
[8] GAO, DOD Personnel Clearances: Additional OMB Actions Are Needed to
Improve the Security Clearance Process, GAO-06-1070 (Washington, D.C.:
Sept. 28, 2006).
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