DOD Personnel Clearances: DOD Needs to Overcome Impediments to	 
Eliminating Backlog and Determining Its Size (09-FEB-04,	 
GAO-04-344).							 
                                                                 
Terrorist attacks and espionage cases have heightened national	 
security concerns and highlighted the need for a timely,	 
high-quality personnel security clearance process. However, GAO's
past work found that the Department of Defense (DOD) had a	 
clearance backlog and other problems with its process. GAO was	 
asked to address: (1) What is the size of DOD's security	 
clearance backlog, and how accurately is DOD able to estimate its
size? (2) What factors impede DOD's ability to eliminate the	 
backlog and accurately determine its size? (3) What are the	 
potential adverse effects of those impediments to eliminating	 
DOD's backlog and accurately estimating the backlog's size? GAO  
was also asked to determine the status of the congressionally	 
authorized transfer of Defense Security Service (DSS)		 
investigative functions and personnel to the Office of Personnel 
Management (OPM).						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-344 					        
    ACCNO:   A09221						        
  TITLE:     DOD Personnel Clearances: DOD Needs to Overcome	      
Impediments to Eliminating Backlog and Determining Its Size	 
     DATE:   02/09/2004 
  SUBJECT:   Counterterrorism					 
	     Investigations by federal agencies 		 
	     National preparedness				 
	     Security clearances				 
	     Personnel classification				 
	     Personnel evaluation				 
	     Internal controls					 
	     Job classification 				 
	     DOD Joint Personnel Adjudication System		 

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GAO-04-344

United States General Accounting Office

GAO Report to the Ranking Minority Member, Committee on Armed Services, House of
                                Representatives

February 2004

DOD PERSONNEL CLEARANCES

  DOD Needs to Overcome Impediments to Eliminating Backlog and Determining Its
                                      Size

GAO-04-344

Highlights of GAO-04-344, a report to the Ranking Minority Member,
Committee on Armed Services, House of Representatives

Terrorist attacks and espionage cases have heightened national security
concerns and highlighted the need for a timely, high-quality personnel
security clearance process. However, GAO's past work found that the
Department of Defense (DOD) had a clearance backlog and other problems
with its process. GAO was asked to address: (1) What is the size of DOD's
security clearance backlog, and how accurately is DOD able to estimate its
size? (2) What factors impede DOD's ability to eliminate the backlog and
accurately determine its size? (3) What are the potential adverse effects
of those impediments to eliminating DOD's backlog and accurately
estimating the backlog's size? GAO was also asked to determine the status
of the congressionally authorized transfer of Defense Security Service
(DSS) investigative functions and personnel to the Office of Personnel
Management (OPM).

GAO recommends that DOD improve its personnel security clearance program's
management and oversight by matching workforce sizes to workloads;
developing a strategic plan to overcome access to information problems;
developing DOD-wide backlog definitions, measures, and reports; and
completing work on the Joint Personnel Adjudication System. DOD concurred
with three recommendations and partially concurred with one.

www.gao.gov/cgi-bin/getrpt?GAO-04-344.

To view the full product, including the scope and methodology, click on
the link above. For more information, contact Derek Stewart, (202)
512-5559, [email protected].

February 2004

DOD PERSONNEL CLEARANCES

DOD Needs to Overcome Impediments to Eliminating Backlog and Determining Its
Size

DOD did not know the size of its security clearance backlog at the end of
September 2003 and has not estimated the size of the backlog since January
2000. DOD cannot estimate the size of its backlog of overdue
reinvestigations that have not been submitted for renewal, but prior
estimates of this portion of the backlog suggest it was sizeable. Using
September 2003 data from DSS, OPM, and nine adjudication facilities, GAO
calculated the size of investigative and adjudicative portions of the
backlog at roughly 270,000 and 90,000 cases, respectively. Because these
estimates were made using time-based goals that varied from agency to
agency, the actual backlog size is uncertain.

Several impediments hinder DOD's ability to eliminate-and accurately
estimate the size of-its clearance backlog. Four major impediments slowing
the elimination of the backlog are (1) the large numbers of new clearance
requests; (2) the insufficient investigator and adjudicator workforces;
(3) the size of the existing backlog; and (4) the lack of a strategic plan
for overcoming problems in gaining access to state, local, and overseas
information needed to complete investigations. Two other factors have
hampered DOD's ability to develop accurate estimates of the backlog size.
DOD has failed to provide adequate oversight of its clearance program,
including developing DOD-wide backlog definitions and measures and using
the measures to assess the backlog regularly. In addition, delays in
implementing its Joint Personnel Adjudication System have limited DOD's
ability to monitor backlog size and track when periodic reinvestigations
are due.

DOD's failure to eliminate and accurately assess the size of the backlog
may have adverse effects. Delays in updating overdue clearances for
command, agency, and industry personnel who are doing classified work may
increase risks to national security. Slowness in issuing new clearances
can increase the costs of doing classified government work. Finally, DOD's
inability to accurately define and measure the backlog and project future
clearance requests that it expects to receive can adversely affect its
ability to develop accurate budgetary and staffing plans.

In December 2003, advisors to OPM's Director recommended that the
authorized transfer of DOD's investigative functions and personnel to OPM
should not occur for at least the rest of fiscal year 2004. That
recommendation was based on uncertainties over financial risks that OPM
might incur. An alternative plan being discussed by DOD and OPM calls for
leaving investigative staff in DSS and giving them training for, and
access to, OPM's case management system. A DOD official estimated that
using the OPM system, instead of DOD's current system, would avoid about
$100 million in update and maintenance costs during the next 5 years.
Also, as of December 16, 2003, the Secretary of Defense had not provided
Congress with certifications required prior to any transfer.

Contents

  Letter

Results in Brief
Background
DOD Unable to Estimate the Size of Its Clearance Backlog
Multiple Impediments Slow DOD's Progress in Eliminating Its

Backlog and Generating Accurate Backlog Estimates Backlogs and Poor
Estimates May Lead to Increased National Security Risks, Higher Costs, and
Workload Uncertainties Status Update on the Authorized Transfer of DSS
Investigative

Functions and Personnel to OPM Conclusions Recommendations for Executive
Action Agency Comments and Our Evaluation 1

4 6 8

13

22

24 26 27 28

Appendix I 	Recent Recommendations Related to DOD's Personnel Security
Clearance Process

Appendix II Scope and Methodology

Appendix III Comments from the Department of Defense

Appendix IV Related GAO Products

  Tables

Table 1: Adjudicative Backlog Present at Each Central Adjudication
Facility, as of September 30, 2003 12 Table 2: Targeted and Actual Numbers
of Requests Submitted to DSS and OPM during Fiscal Years 2001-2003 15

  Figures

Figure 1: DOD's Personnel Security Clearance Process
Figure 2: Estimated Backlog Size at Each Stage in the Personnel

7

Security Clearance Process, as of September 2003 9

Abbreviations

DOD Department of Defense
DSS Defense Security Service
JPAS Joint Personnel Adjudication System
OPM Office of Personnel Management
OASD (C3I) Office of the Assistant Secretary of Defense for Command,

Control, Communications, and Intelligence OUSD (I) Office of the Under
Secretary of Defense for Intelligence

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separately.

United States General Accounting Office Washington, DC 20548

February 9, 2004

The Honorable Ike Skelton Ranking Minority Member Committee on Armed
Services House of Representatives

Dear Mr. Skelton:

Recent events, such as the terrorist attacks on the United States on
September 11, 2001, and several high-profile espionage cases have
heightened national security concerns and underscored the need for a
timely, high-quality personnel security clearance process. Each year, the
Department of Defense (DOD) processes hundreds of thousands of security
clearance requests for service members, government employees, and industry
personnel who are conducting classified work for the department and other
government agencies. These requests include (1) periodic reinvestigations
for individuals who already hold security clearances or initial
investigations for individuals who have not held security clearances in
the past and (2) adjudications to determine whether or not individuals are
eligible for clearances, based on information collected during the
investigations and reinvestigations.

Historically, DOD's Defense Security Service (DSS) had conducted almost
all of the department's security clearance investigations. In 1999,
however, DOD contracted with the Office of Personnel Management (OPM), and
later with private-sector investigative firms, to process large numbers of
new investigations and reinvestigations. Using information from the
investigations, DOD's 10 central adjudication facilities provide the
eligibility-for-clearance determinations.

Since at least the late 1990s, the timeliness of DOD's personnel security
clearance process has been at issue. In our October 1999 report,1 for
example, we identified serious problems with the adequacy of DOD's
investigations; this work prompted the department to declare its

1 U.S. General Accounting Office, DOD Personnel: Inadequate Personnel
Security Investigations Pose National Security Risks, GAO/NSIAD-00-12
(Washington, D.C.: Oct. 27, 1999).

investigative function a systemic weakness2 under the Federal Managers'
Financial Integrity Act of 1982.3 In our August 2000 report, we noted that
DOD estimated it had a backlog of more than 500,000 overdue
reinvestigations that had not yet been submitted for renewal and found
that DOD had no established method for monitoring or estimating the total
number of periodic reinvestigations that were overdue but not submitted.4
Moreover, in our 2001 report, we found that DOD's adjudicators did not
consistently document adverse security conditions, and we identified other
factors that hindered the effectiveness of the adjudication process.5
Along with our reviews, several reports issued in 2000 and 2001 by the DOD
Office of the Inspector General have also documented problems with various
aspects of the security clearance process.6 In agency comments to GAO and
DOD Office of Inspector General recommendations (see app. I for
recommendations), DOD identified many actions it had taken or planned to
take to address problems in its investigative and adjudicative processes.
For example, in response to a recommendation in our August 2000 report,
DOD noted that the Joint Personnel Adjudication System

2 In DOD's Annual Statement of Assurance, FY 1999 Volume I, DOD stated
that "[i]n the upcoming annual assurance statement, Defense Security
Service (DSS) will identify the Personnel Security Investigations Program
as being a material weakness and will provide an action plan that
addresses corrective actions needed to bring the program back into
compliance with performance expectations and with existing security
policies." However, in both the fiscal year 2000 and 2001 Annual Statement
of Assurance, the personnel security investigations program was listed as
a systemic weakness. According to the fiscal year 2001 Statement of
Assurance, "Material weaknesses are management control problems that
affect only one Component and do not significantly impact mission
accomplishment. Systemic weaknesses are management control problems that
affect more that one DOD Component and may jeopardize the Department's
operations." Department of Defense, Annual Statement of Assurance, Vol. I
(Washington, D.C.: 1999).

3 Pub. L. 97-255 (Sept. 8, 1982).

4 U.S. General Accounting Office, DOD Personnel: More Actions Needed to
Address Backlog of Security Clearance Reinvestigations, GAO/NSIAD-00-215
(Washington, D.C.: Aug. 24, 2000).

5 U.S. General Accounting Office, DOD Personnel: More Consistency Needed
in Determining Eligibility for Top Secret Security Clearances, GAO-01-465
(Washington, D.C.: Apr. 18, 2001).

6 Department of Defense, Office of Inspector General Audit Report, Program
Management of the Defense Security Service Case Control Management System,
Report No. D-2001-019 (Arlington, Va.: Dec. 15, 2000); Department of
Defense, Office of Inspector General Audit Report, Acquisition Management
of the Joint Personnel Adjudication System, Report No. D-2001-112
(Arlington, Va.: May 5, 2001); and Department of Defense, Office of
Inspector General Audit Report, Security Clearance Investigative
Priorities, Report No. D-2000-111 (Arlington, Va.: Apr. 5, 2000).

(JPAS) would be implemented in fiscal year 2001 and would provide an
automated means of tracking and counting overdue but-not-submitted
requests for reinvestigation.

More recently, the National Defense Authorization Act for Fiscal Year 2004
authorized the transfer of DOD's personnel security investigative
functions and 1,855 investigative employees to OPM.7 Under the Act, a
transfer of functions can only be made after the Secretary of Defense
certifies that certain conditions can be met and that the Director of OPM
concurs with the authorized transfer. Among the conditions requiring
Secretary of Defense certification are "[t]hat the Office of Personnel
Management is fully capable of carrying out high-priority investigations
required by the Secretary of Defense within a timeframe set by the
Secretary of Defense" and "[t]hat the Office of Personnel Management has
undertaken necessary and satisfactory steps to ensure that investigations
performed on Department of Defense contract personnel will be conducted in
an expeditious manner sufficient to ensure that those contract personnel
are available to the Department of Defense within the timeframe set by the
Secretary of Defense."

You asked us to conduct a follow-up review of DOD's personnel security
process. As agreed with your office, this report addresses three
questions: (1) What is the size of DOD's security clearance backlog, and
how accurately is DOD able to estimate its size? (2) What factors impede
DOD's ability to eliminate the backlog and accurately determine its size?
(3) What are the potential adverse effects of those impediments to
eliminating DOD's backlog and accurately estimating the backlog's size? In
addition to answering these three questions, you asked us to determine the
status of the congressionally authorized transfer of DSS investigative
functions and personnel to OPM.

To conduct our work, we reviewed DOD and OPM regulations, instructions,
policy guidance, and available empirical data and procedural information
on the personnel security clearance process. In addition, we obtained
information during meetings with DOD, OPM, and other officials who are
responsible for the oversight, investigative, and adjudicative functions
of the personnel security clearance process. We also referred to prior
GAO, DOD Office of Inspector General, and congressional reports. We
conducted our work from February through December 2003 in

7 Pub. L. 108-136 S: 906 (Nov. 24, 2003).

  Results in Brief

accordance with generally accepted government auditing standards.
Additional information on our scope and methodology is presented in
appendix II.

DOD did not know the size of its security clearance backlog at the end of
September 2003 and has not estimated the size of the backlog since January
2000. DOD cannot estimate the size of its backlog of overdue
reinvestigations that have not yet been submitted for renewal, but prior
estimates of this portion of the backlog have been sizeable. For example,
we noted in our 2000 report that DOD estimated its number of
overduebut-not-submitted reinvestigations at 300,000 cases in 1986 and at
500,000 cases in 2000. Based on September 2003 data that we obtained from
DSS, OPM, and adjudication facilities, we estimated the potential size of
DOD's investigative and adjudicative backlogs to be roughly 270,000 and
90,000 cases, respectively. Because these estimates were developed using
time limits for completing investigations or adjudications that varied
from agency to agency, uncertainty is present regarding the actual size of
the backlog.

A number of impediments hinder DOD's ability to eliminate its security
clearance backlog and accurately estimate the size of the backlog. Four
major impediments have slowed DOD's progress in eliminating the backlog.
(1) The large number of new requests for clearances has hampered DOD's
efforts to draw down the number of cases already in DOD's current backlog.
(2) The sizes of the investigator and adjudicator workforces have not been
sufficient to eliminate the backlog, even though DOD has taken steps to
increase the number of requests that can be processed. For example,
according to an OPM official, roughly 8,000 full-time-equivalent
investigative personnel are needed to eliminate the backlog, but our
calculations showed that DOD and OPM have around 4,200
full-time-equivalent government and contract investigative staff as of
December 2003. (3) The mere size of the existing backlog has prevented the
timely processing and completion of new requests for clearances. (4) The
lack of a strategic plan for overcoming problems in gaining access to
state, local, and overseas information has slowed the completion of
investigations and thereby has impeded the reduction of the backlog. In
addition, two other factors have hampered DOD's ability to develop
accurate estimates of the backlog. DOD has failed to provide adequate
oversight for the security clearance program, including developing
DOD-wide definitions and measures of the backlog and using the measures to
assess the backlog regularly. In addition, delays in implementing JPAS

have limited DOD's ability to, among other things, monitor backlog size
and track when periodic reinvestigations are due.

DOD's failure to eliminate its large security clearance backlog and to
accurately estimate the size of the backlog may have adverse effects. For
example, delays in updating overdue clearances for command, agency, and
industry personnel performing classified government work may increase
risks to national security. Similarly, delays in issuing initial
clearances caused by the backlog and other impediments can increase the
costs of doing classified government work. In addition, DOD's inability to
accurately define and measure the backlog and project the number of future
clearance requests it expects to receive can adversely affect DOD's
ability to develop accurate budgetary and staffing plans. For example,
DOD's difficulty in estimating its workload was evidenced in fiscal year
2002 when DOD expected 720,000 requests for investigations and actually
received more than 850,000 requests-or 18 percent more.

In December 2003, advisors to the Director of OPM recommended that the
congressionally authorized transfer of DOD's investigative functions to
OPM should not take place for at least the rest of fiscal year 2004. That
recommendation was based on uncertainty about the financial risks that OPM
might incur from the transfer. The advisors recommended an alternative
plan that is currently being discussed by DOD and OPM officials. The
alternative plan would keep DSS's investigative staff in DOD; provide DSS
with access to OPM's case management system, which, according to a DOD
official, would save about $100 million in costs associated with
continuing to update and maintain DOD's current case management system;
and train DSS staff to use that system. Also, as of December 16, 2003, the
Secretary of Defense had not provided Congress with the certifications
that are required before the transfer could take place.

In order to eliminate the personnel security clearance backlog and
increase the accuracy of DOD's security clearance backlog estimates, we
are recommending that DOD take steps to improve the management and
oversight of the personnel security clearance program: match both
investigative and adjudicative workforce sizes to workloads; develop a
strategic plan to overcome access to information problems; develop
DOD-wide backlog definitions and measures and monitor the backlog; and
complete the implementation of JPAS.

Background

In commenting on a draft of this report, DOD fully concurred with three of
our four recommendations and partially concurred with our recommendation
to match workforce sizes to workloads.

The Office of the Under Secretary of Defense for Intelligence (OUSD (I))
was created in 2002 with the passage of the Bob Stump National Defense
Authorization Act for Fiscal Year 2003.8 Among the responsibilities of
OUSD (I) are the coordination and implementation of DOD policy for access
to classified information. At the time of our earlier review on the
clearance process, these responsibilities belonged to the Office of the
Assistant Secretary of Defense for Command, Control, Communications, and
Intelligence (OASD (C3I)).

Classified information is categorized into three levels-top secret,
secret, and confidential-to denote the degree of protection required for
information according to the amount of damage that unauthorized disclosure
could reasonably be expected to cause to national defense or foreign
relations.9 The degree of expected damage that unauthorized disclosure
could reasonably be expected to cause is "exceptionally grave damage" for
top secret information, "serious damage" for secret information, and
"damage" for confidential information. To retain access to classified
information, individuals must periodically go through the security
clearance process. The time frames for reinvestigation are every 5 years
for top secret, 10 years for secret, and 15 years for confidential.10

DOD's personnel security clearance process has three stages:
preinvestigation, which includes determining if a requirement for access
exists and submitting an investigation request; the actual personnel
security investigation; and adjudication, a determination of eligibility
for access to classified information (see fig. 1). Since 1997, all federal
agencies

8 Pub. L. 107-314 S: 901 (Dec. 2, 2002).

9 Classification of National Security Information, 5 C.F.R. S:1312.4
(2003).

10 Adjudicative Guidelines for Determining Eligibility for Access to
Classified Information, 32 C.F.R. Part 147, Subpart B, Attach. A and
Attach. C (2003).

have been subject to a common set of personnel security investigative
standards and adjudicative guidelines for determining whether service
members, government employees, industry personnel, and others are eligible
to receive a security clearance.11 In 1998, DOD formally incorporated
these standards and guidelines into its regulations governing access to
classified information.12

Figure 1: DOD's Personnel Security Clearance Process

The security officer begins the preinvestigation stage of the clearance
process by determining whether a position requires access to classified
information. If so, the current or future job incumbent completes a
personnel security questionnaire that asks for detailed information about
a wide range of issues. The impetus for an investigation request could be
a need to (1) appoint, enlist, or induct an individual into the military;
(2) staff a new program or contract with an individual who has a
clearance; (3) replace a cleared job incumbent with someone else; (4)
raise an existing clearance to a higher level; or (5) reinvestigate a
previously cleared job incumbent whose clearance is due for
reinvestigation.

In the investigation stage, investigative staff members seek information
pertaining to the subject's loyalty, character, reliability,
trustworthiness, honesty, and financial responsibility. The level of
clearance is the primary

11 The White House, "Implementation of Executive Order 12968," Memorandum,
(Washington, D.C.: Mar. 24, 1997). This memorandum approves the
adjudicative guidelines, temporary eligibility standards, and
investigative standards required by Executive Order 12968, Access to
Classified Information, Aug. 2, 1995.

12 Assistant Secretary of Defense for Command, Control, Communications,
and Intelligence, "Personnel Security Investigations and Adjudications,"
Memorandum (Washington, D.C.: Nov. 10, 1998).

  DOD Unable to Estimate the Size of Its Clearance Backlog

determinant of the types and sources of information gathered. For example,
an investigation for a top secret clearance requires much more information
than does the type of investigation required to determine eligibility for
either a secret or confidential clearance. The types or sources of
information might include an interview with the subject of the
investigation, national agency checks (e.g., Federal Bureau of
Investigations and immigration records), local agency checks (e.g.,
municipal police and court records), financial checks, birth date and
place, citizenship, education, employment, public records for information
such as bankruptcy or divorce, and interviews with references.

In the adjudication stage of the security clearance process, government
employees in 10 DOD central adjudication facilities13 use the information
gathered at the investigation stage to approve, deny, or revoke
eligibility to access classified information. Once adjudicated, the
security clearance is then issued up to the appropriate eligibility level,
or alternative actions are taken if eligibility is denied or revoked.

DOD did not know the size of its personnel security clearance backlog and
has not estimated the size of the backlog since January 2000. DOD was
unable to estimate the size of its backlog for overdue reinvestigations
that have not yet been submitted, but our estimates for overdue submitted
investigation requests and overdue adjudications were roughly 270,000 and
90,000 cases, respectively, at the end of September 2003. These estimates
are not based on a consistent set of DOD-wide definitions

13 A Defense Personnel Security Research Center report provided the
following distinctions in the roles of the 10 DOD central adjudication
facilities. The Army, Navy, and Air Force facilities adjudicate all
military and civilian clearances for their respective services, and the
sensitive compartmented information clearances for industry employees
working on the department's contracts. The Washington Headquarters Service
facility adjudicates all clearances, except for sensitive compartmented
information, for civilians assigned to Defense agencies. The National
Reconnaissance Office, National Security Agency, and Defense Intelligence
Agency facilities adjudicate all sensitive compartmented information
clearances for their own employees, and the Defense Intelligence Agency
also does the same for other Defense agency civilians. The Joint Chiefs of
Staff facility adjudicates clearances for its own personnel. The Defense
Industrial Security Clearance Office adjudicates investigations that
contain favorable or minor derogatory information for issuance of top
secret, secret, and confidential clearances for industry personnel.
Industry investigations that contain major derogatory information are
transferred to the Defense Office of Hearings and Appeals for
adjudication. Ralph M. Carney et al., Quality Assurance in Defense
Adjudication: An Adjudicator Workshop for Defining and Assessing Quality,
(Monterey, Calif.: Defense Personnel Security Research Center, Mar. 2003).

and measures; instead, the time limits for defining and measuring the
backlog varied from agency to agency.

DOD Unable to Estimate DOD could not estimate the number of personnel who
had not requested the Number of Overdue a reinvestigation, even though
their clearances exceeded the Reinvestigations Not Yet governmentwide time
frames for reinvestigation (see fig. 2). As we Submitted mentioned
earlier, the governmentwide time frames for renewing

clearances are 5, 10, or 15 years depending on an individual's clearance
level. We, therefore, defined this portion of the backlog as any request
for reinvestigation that had not been submitted within those time frames.

Figure 2: Estimated Backlog Size at Each Stage in the Personnel Security
Clearance Process, as of September 2003

In our 2000 report, we indicated that DOD estimated its overdue but-not

submitted reinvestigation backlog at 300,000 cases in 1986 and 500,000

cases in 2000.14 Our 2000 report also noted that the 500,000-case backlog

estimate was of questionable reliability because of the ad hoc methods

used to derive it. Between 2000 and 2002, DOD took a number of steps to

reduce this backlog, including mandating the submission of requests and

requiring senior service officials to provide monthly submission progress

reports. On February 22, 2002, DOD concluded this backlog reduction

14 GAO/NSIAD-00-215.

effort by issuing an OASD (C3I) memorandum directing that "[b]y September
30, 2002, if a clearance is not based upon a current or pending
investigation, or if the position does not support a requirement for a
clearance, the clearance must be administratively terminated or downgraded
without prejudice to the individual." DOD is unable to show that the
overdue but-not-submitted reinvestigations backlog was eliminated by these
actions.

    Roughly 270,000 Submitted Requests for Investigations Overdue for
    Completion

At the end of September 2003, the investigative portion of the backlog
consisted of roughly 270,000 submitted requests for either reinvestigation
or initial investigation that had not been completed within a prescribed
amount of time. We calculated this estimate from information provided in
response to the data requests that we made to DSS and OPM. This number
represents an estimated 163,000 cases at DSS and 107,000 cases contracted
to OPM that had not been completed within the time limits. In our August
2000 report, DOD stated that a vast majority of 94,000 submitted requests
for reinvestigation were overdue for completion, and those cases were not
part of DOD's estimate of 500,000 overdue but-not-submitted
reinvestigations discussed in the prior section. At that time, DOD had not
included either submitted reinvestigations or initial investigations that
exceeded specified time limits as part of the DOD-wide backlog. An
estimate of the initial investigations exceeding the time limit was not a
focus of that work.

The existence of varying sets of time limits for completing investigations
makes it difficult to develop accurate estimates of the size of DOD's
investigative backlog.

o  	DSS's performance goals are 120 days for a periodic reinvestigation
for a top secret clearance, 90 days for an initial top secret clearance,
and 75 days for either a secret or confidential clearance being issued
initially.15 In addition, some requests for investigations receive
priorities

over other requests.

o  	OPM has timeliness categories that DOD and other agencies use to
request various types of investigations. The timeliness categories are

15 DSS's performance goal is to complete at least 75 percent of each type
of investigation within the specified time limits, but monitoring of the
backlog requires a determination of whether each investigation was
completed by the time limit-not whether an aggregate performance goal was
met for a particular type of investigation.

35 days for priority investigations, 75 days for accelerated
investigations, 120 days for standard investigations, and 180 days for
extended service agreements.16

The lack of a standard set of time limits is a long-standing problem. In
1994, the Joint Security Commission reported on this issue, and among
other things (1) found there was no performance standard for timeliness in
completing investigations and adjudications, (2) stated it repeatedly
heard from the customer community that 90 days is an appropriate standard
for completing an average investigation and adjudication, and (3)
recommended "[s]tandard measurable objectives be established to assess the
timeliness and quality of investigations, adjudications, and
administrative processes and appeals performed by all such organizations
within DOD and the Intelligence Community."17

OPM's issuance of closed pending cases-investigations sent to adjudication
facilities without one or more types of source data-presents another
ambiguity in defining and accurately estimating the backlog. In our
October 1999 report, we found that DSS had similarly delivered incomplete
investigations to DOD adjudicators.18 After we recommended that DOD
adjudication facility officials grant clearances only when all essential
investigative work has been done, DSS monitored the cases returned from
the adjudication facilities and identified reasons for the returns.
Overall, about 10 percent of the 283,480 DOD cases fully closed by OPM in
fiscal year 2002 were initially delivered to central adjudication
facilities as closed pending cases. When measuring the timeliness of its
contractors' performance, OPM defines completed investigations as cases
that (1) have the complete information required for the type of
investigation, (2) are closed pending, or (3) have been discontinued. If
the investigations have not been fully completed within OPM-contracted
time limits, we believe that closed pending cases should be included in
the investigative portion of the backlog.

16 OPM's performance goals for its contractor are to complete 90 percent
of the 35-day service requests by the agency date, 92 percent of the
75-day service requests by the agency date, 95 percent of the 120-day
service requests by the agency date, and 95 percent of the extended
service agreements by the agency date.

17 Joint Security Commission, Redefining Security: A Report to the
Secretary of Defense and the Director of Central Intelligence (Washington,
D.C.: Feb. 28, 1994).

18 GAO/NSIAD-00-12.

    DOD-Wide Estimate of Adjudicative Backlog Exceeds Roughly 90,000 Cases

Central adjudication facilities' responses to our request for adjudicative
backlog estimates as of September 30, 2003, indicated that roughly 90,000
completed investigations had not been adjudicated within prescribed time
limits (see table 1). Differences in the sizes of the backlog at the
various central adjudication facilities are due to a combination of
factors. For example, the military service departments generally perform
more adjudications than do DOD agencies; some facilities have increased
their staffing of government employees to decrease the backlog; and some
facilities have contracted for support services to decrease the backlog.
We later discuss the large number of requests that have resulted over the
last few years. DOD officials attributed this extra adjudicative workload
to, among other things, increased operations related to the war on
terrorism.

Table 1: Adjudicative Backlog Present at Each Central Adjudication
Facility, as of September 30, 2003

           Central Adjudication Facility Size of Adjudicative Backlog

                                  Army 35,226

                                Air Force 25,493

              Defense Industrial Security Clearance Office 12,793

                                  Navy 12,606

                  Defense Office of Hearings and Appeals 4,487

                     Washington Headquarters Services 1,296

                       Defense Intelligence Agency 1,046

National Security Agency

                           Joint Staff does not track

                                  Total 92,947

Source: DOD.

Note: We did not attempt to gather information from the National
Reconnaissance Office because of the sensitive nature of its mission.

An ambiguous picture of the adjudicative backlog size is present because
the central adjudication facilities use different time limits to define
when cases become part of the backlog. Applying the backlog criteria of
one central adjudication facility to the completed investigations waiting
adjudication at another facility could increase or decrease the estimated
size of the DOD-wide adjudicative backlog. For instance, the Defense
Industrial Security Clearance Office's goals for completing adjudications
are 3 days for initial investigations and 30 days for periodic
reinvestigations, and any cases exceeding these amounts are considered a
backlog. In contrast, the Defense Office of Hearings and Appeals' goal is
to

maintain a steady workload of adjudicating 2,150 cases per month within 30
days of receipt, and it considers a backlog to exist when the number of
cases on hand exceeds its normal workload. Thus, if the Defense Industrial
Security Clearance Office's stricter time limit were applied to the
initial investigations awaiting adjudication at the Defense Office of
Hearings and Appeals, the latter office's backlog would be larger than
that currently reported.

We have identified four major impediments that have slowed DOD's progress
in eliminating its clearance backlog and two impediments that have
hindered its ability to produce accurate backlog estimates.

                              Multiple Impediments

  Slow DOD's Progress in Eliminating Its Backlog and Generating Accurate Backlog
  Estimates

    Large Number of Clearance Requests, Limited Staffing, Existing Backlog, and
    No Strategic Plan for Information-Access Problems Slow DOD's Efforts to
    Eliminate the Backlog

Large Number of Requests for Clearances

In our review of documents and discussions with officials from DOD, OPM,
industry associations, and investigator contractors, we identified four
major impediments that have hampered DOD's ability to eliminate its
current security clearance backlog. These are: (1) the large number of new
requests for clearances, (2) inadequate investigator and adjudicator
workforces, (3) the mere size of the existing backlog, and (4) the lack of
a strategic plan for overcoming problems by government and contractor
investigators in gaining access to information from state, local, and
overseas sources.

The large number of requests for security clearances hinders DOD's efforts
to draw down the number of cases in its current clearance backlog. In
fiscal year 2003, the Secretary of Defense annual report to the President
and Congress noted that defense organizations annually request more than 1
million security checks. These checks include investigations that are part
of the personnel security clearance process as well as other
investigations such as those used to screen some new recruits entering the
military. Other federal agencies are also requesting a growing number of
background investigations according to OPM. In our November 2003

report on aviation security,19 we noted that OPM had stated that (1) it
received an unprecedented number of requests for background investigations
governmentwide since September 2001 and (2) the large number of requests
was the primary reason for delayed clearance processing.

Historically, almost all of DOD's requests for investigations were
submitted to DSS. Starting in 1999, DOD contracted with OPM to complete a
large number of requests for investigations as part of DOD's effort to
expand its investigative capacity and decrease its investigative backlog.
OUSD (I) estimated that DOD spent over $450 million for the investigations
submitted to DSS and OPM in fiscal year 2003. As table 2 shows, OUSD (I)
reported that the actual number of requests submitted for investigations
were approximately 700,000 in fiscal year 2001, more than 850,000 in
fiscal year 2002, and more than 775,000 in fiscal year 2003.20 In fiscal
year 2003, DSS had responsibility for a larger percentage of the total DOD
investigations workload than it had in the prior 2 fiscal years. DSS
supplemented its federal workforce with contracts to three privatesector
investigations firms. As table 2 also indicates, the number of targeted
submissions versus the actual number of submissions that DOD received
varied considerably from year to year. In fiscal year 2001, DOD received
fewer requests than it had expected (82 percent), and in fiscal years 2002
and 2003, it received more requests than projected (119 and 113 percent,
respectively).

19 U.S. General Accounting Office, Aviation Security: Federal Air Marshal
Service Is Addressing Challenges of Its Expanded Mission and Workforce,
but Additional Actions Needed, GAO-04-242 (Washington, D.C.: Nov. 19,
2003).

20 In our October 1999 report on investigations, table 9 showed that
during fiscal years 1991-1998, DSS opened a low of 126,000 cases in fiscal
year 1996 and a high of 271,000 cases in fiscal year 1992. We believe that
differences in investigative procedures and other conditions at DSS then
versus now make findings from any such comparison of prior and current
investigative workloads tenuous. GAO/NSIAD-00-12.

Table 2: Targeted and Actual Numbers of Requests Submitted to DSS and OPM
during Fiscal Years 2001-2003

                                  FY 2001         FY 2002         FY 2003     
                     Requests                                 
                 submitted to  Target Actual  Target Actual     Target Actual 
                          DSS 435,734 416,233 408,539 438,093 530,271 603,460 
                          OPM 413,033 283,963 312,248 418,181 157,004 173,984 
                        Total 848,767 700,196 720,787 856,274 687,275 777,444 
         Percent of actual at            59 %            51 %            78 % 
                          DSS                                 
            Percent of target            82 %           119 %           113 % 

Source: OUSD (I).

Note: Table 2 shows when investigations began, but the investigations may
not be completed in the same fiscal year.

DOD personnel, investigations contractors, and industry officials told us
that the large number of requests for investigations could be attributed
to many factors. For example, they ascribed the large number of requests
to heightened security concerns that resulted from the September 11, 2001,
terrorist attacks. They also attributed the large number of investigations
to an increase in the operations and deployments of military personnel and
to the increasingly sensitive technology that military personnel,
government employees, and contractors come in contact with as a part of
their job. While having a large number of cleared personnel can give the
military services, agencies, and industry a large amount of flexibility
when assigning personnel, the investigative and adjudicative workloads
that are required to provide the clearances further tax DOD's already
overburdened personnel security clearance program.

A change in the level of clearance being requested also increases the
investigative and adjudicative workloads. A growing percentage of all DOD
requests for clearances is at the top secret level. For example, in fiscal
years 1995 and 2003, 17 percent and 27 percent, respectively, of the
clearance requests for industry personnel were at the top secret level.
This increase of 10 percentage points in the proportion of investigations
at the top secret level is important because top secret clearances must be
renewed twice as often as secret clearances (i.e., every 5 years versus
every 10 years). According to OUSD (I), top secret clearances take eight
times the investigative effort needed to complete a secret clearance and
three times the adjudicative effort to review. The doubling of frequency

Inadequate Investigative and Adjudicative Workforces Hinder Efforts to
Eliminate Backlog

along with the increased effort to investigate and adjudicate each top
secret reinvestigation adds costs and workload for DOD.

o  	Cost. In fiscal year 2003, the costs of investigations that DOD
obtained through DSS were $2,640 for an initial investigation for a top
secret clearance, $1,591 for a periodic reinvestigation of a top secret
clearance, and $328 for the most commonly used investigation for a secret
clearance. The cost of getting and maintaining a top secret clearance for
10 years is approximately 13 times greater than the cost for a secret
clearance. For example, an individual getting a top secret clearance for
the first time and keeping the clearance for 10 years would cost DOD a
total of $4,231 in current year dollars ($2,640 for the initial
investigation and $1,591 for the reinvestigation after the first 5 years).
In contrast, an individual receiving a secret clearance and maintaining it
for 10 years would cost a total of $328 ($328 for the initial clearance
that is good for 10 years).

o  	Time/Workload. The workload is also affected by the scope of coverage
in the various types of investigations. Much of the information for a
secret clearance is gathered through electronic files. The investigation
for a top secret clearance, on the other hand, requires the information
needed for the secret clearance as well as data gathered through
time-consuming tasks such as interviews with the subject of the
investigation request, references in the workplace, and neighbors.

Another impediment to eliminating the large security clearance backlog is
the inadequate size of the federal and private-sector investigative
workforces relative to the large workloads that they face. The Deputy
Associate Director of OPM's Center for Investigations Services estimated
that roughly 8,000 full-time-equivalent investigative personnel would be
needed by OPM and DOD (together) to eliminate backlogs and deliver
investigations in a timely fashion to their customers. The rough estimate
includes investigators and investigative technicians. However, changes in
the numbers or types of clearance requests, different levels of
productivity by investigators, and other factors could greatly affect this
estimated workforce requirement.

As of December 2003, we calculated that DOD and OPM have around 4,200
full-time-equivalent investigators available as federal employees or
currently under contract. Of this number, DSS indicated that it has about
1,200 investigators and 100 investigative technicians. In addition, DSS
has the equivalent of 625 full-time investigative staff, based on 2,500
mostly

part-time investigators, from its three contractors. DSS equates four of
the part-time investigators to one full-time investigator. Finally,
although OPM has almost no investigative staff currently, its primary
contractor has approximately 2,300 full-time investigators. OPM reported
that its primary contractor is adding about 100 investigators per month,
but turnover is about 70 employees per month.

We believe that DSS's estimate of the number of full-time-equivalent
investigators working for its contractors is imprecise because (1) an
investigator may work part-time for more than one contractor and (2) the
amount of time devoted to conducting investigations can vary
substantially. These part-time investigators work different amounts of
time each month, according to both their own preference and the number of
assignments they receive from investigation contractor(s). Sometimes they
are unavailable to work for one contractor because they are conducting
investigations for another contractor. Officials from DSS's investigations
contractors told us that they intend to continue relying largely on staff
employed on an as-needed basis. Some of the private-sector officials
stated that they would incur additional financial risks if they were to
use full-time investigators.

Inadequate adjudicator staffing also causes delays in issuing
eligibility-forclearance decisions. Since we issued our report on DOD
adjudications in 2001, the number of eligibility-for-clearance decisions
has risen for reasons such as an increase in the number of completed
investigations stemming from DOD's contract with OPM and the improved
operation of DSS's Case Control Management System.

Central adjudication facilities with adjudicative backlogs have taken
various actions to eliminate their backlog. The Defense Office of Hearings
and Appeals hired 46 additional adjudicators on 2-year term appointments,
contracted for administrative functions associated with adjudication, and
is seeking permission from the Office of the Secretary of Defense to hire
some of its term adjudicators permanently. The Navy's central adjudication
facility contracted with three companies to provide support and hired an
additional 27 full-time-equivalent civilian and military adjudicators,
which helped the Navy eliminate much of its adjudicative backlog that had
grown to approximately 60,000 cases by December 2002. Because the DOD
Office of Inspector General is examining whether the Navy adjudicative
contracts led the contractor's staff to perform an inherently governmental
function-adjudication-it is unclear whether the Army and Air Force central
adjudication facilities will be able to use similar contracting to
eliminate their backlogs.

Size of Existing Backlog Impedes Prompt Opening of New Requests for
Investigation

The 10 DOD central adjudication facilities are funded by different
agencies and operate independently of one another. As a result, OUSD (I)
cannot transfer backlogged cases from one facility to eliminate an
adjudicative backlog at another facility. In our April 2001 report on DOD
adjudications,21 we noted that studies issued by the Defense Personnel
Security Research Center, the Joint Security Commission, and the DOD
Office of the Inspector General between 1991 and 1998 had concluded that
the decentralized structure of DOD's adjudication facilities had
drawbacks. Two of the studies had recommended that DOD consolidate its
adjudication facilities (with the exception of the National Security
Agency because of the sensitive nature of its work) into a single entity.
Currently, OUSD (I) is exploring the possibility of assigning all industry
adjudications to the Defense Industrial Security Clearance Office instead
of having it share this responsibility with the Defense Office of Hearing
and Appeals.

The current size of the investigative backlog impedes DOD's ability to
process new security clearance requests within the prescribed time limits.
A new request might remain largely dormant for months in the
investigations queue until other requests that were received earlier have
been completed. This point can be illustrated by examining the results of
miscommunications between OASD (C3I) and DSS regarding assigning
priorities to investigations between March 2002 and March 2003. During
that period, DSS placed a higher priority on completing new-versus old-
requests. From March through September 2002, DSS averaged 97 days to open
and complete initial investigation requests for top secret clearances; 100
days, for top secret reinvestigation; 43 days, for secret; and 44 days,
for confidential. For three of the four types of investigations, DSS's
average completion times were faster than its time-based goals (120 days
for a periodic reinvestigation for a top secret clearance, 90 days for an
initial top secret clearance; and 75 days for either a secret or
confidential clearance being issued initially). Starting in March 2003,
DSS again assigned a higher priority to older requests. However, during
those 12 months, from March 2002 to February 2003, the average age of the
older cases increased, and it is impossible to say how much of the
increase was due to the miscommunication regarding priorities, a change in
the number of requests that DSS received, or some other factor.

21 GAO-01-465.

No Strategic Plan for Overcoming Information-Access Problems Slows
Investigative Process

DSS staff told us that the delays in starting investigations could lead to
additional delays in processing the case, particularly for military
personnel who were being deployed or were moving. Therefore, DSS
instituted a procedure to attempt to meet with individuals requesting an
investigation before they deploy or go on extended training. Delays in
starting investigations can result in extra investigative work to find the
individuals at their new addresses or additional delays if investigators
wait for the individuals to return from deployment or training. In some
cases, however, DOD commands, agencies, and contractors have been able to
obtain some investigations quickly by assigning higher priorities to
certain individual investigations or types of investigations.

The absence of a strategic plan for overcoming problems in gaining access
to information from state and local agencies also slows the speed of
personnel security clearance investigations and, thereby, impedes reducing
the size of the backlog. Investigators face delays in conducting
background checks because of the lack of automated records in many
localities, state and local budget shortfalls that limit how much time
agency staff have to help investigators, and privacy concerns (e.g.,
access to conviction records from the courts instead of the preferred
arrest records from law enforcement). This problem of accessibility to
state and local information was identified in an October 2002 House
Committee on Government Reform report.22 The report recommended that the
Secretary of Defense and the Attorney General jointly develop a system
that allows DSS and OPM investigators access to state and local criminal
history information records. In addition, representatives from one
investigations contractor noted that the Security Clearance Information
Act23 gives only certain federal agencies access to state and local
criminal records, and therefore private-sector investigators are put at a
disadvantage relative to federal investigators.

Another barrier to the timely closure of an investigation is a limited
investigative capacity overseas, which causes delays in obtaining
information from overseas investigative sources. DSS, OPM, and
privatesector investigations contractors do not maintain staffs overseas
to investigate individuals who are currently or were formerly stationed

22 Committee on Government Reform, Defense Security Service: The Personnel
Security Investigations (PSI) Backlog Poses a Threat to National Security,
H.R. 107-767 (Washington, D.C.: Oct. 24, 2002).

23 Security Clearance Information Act, 5 U.S.C. S: 9101 (2003).

overseas, who have traveled or lived overseas, or who have relatives
living in foreign countries. Officials at DSS and the central adjudication
facilities told us that they typically ask overseas-based DOD criminal
investigations personnel or State Department and Central Intelligence
Agency employees to supply this type of investigative information as a
collateral duty.

DOD has no strategic plan for overcoming access to information problems
and the delays that result, but DOD has made efforts to address selective
aspects of the access problem. For example, DOD supplied us with draft
legislation proposing to provide access to a central repository for driver
licensing records. DOD proposed that this information be used in personnel
security investigations and determinations as well as personnel
investigations with regard to federal employment security checks. Also, an
OUSD (I) official noted that DOD proposed a legislative change for the
fiscal year 2001 authorization bill to allow easier access to records of
criminal history information.

    Oversight Problems and Automation Delays Hinder Accurate Monitoring of
    Backlog Size

OUSD (I) and its predecessor OASD (C3I) have not provided the oversight
needed to monitor and accurately estimate the various parts of the backlog
that are present throughout DOD. Also, as we documented earlier, backlog
estimates are not based on a consistent set of DOD-wide definitions and
measures. Knowing the accurate size of the backlog is an important step
towards effectively managing and eventually eliminating the backlog. When
we asked for all investigative backlog reports produced since 2000, OUSD
(I) supplied January 2000 estimates as its most recent report, and the
report included only reinvestigations. This finding regarding the
infrequency of reporting contradicts DOD's concurrence with our October
1999 recommendation for OASD (C3I) to improve its oversight of the
investigations program and our August 2000 recommendation to design
routine reports to show the full extent of overdue reinvestigations. Our
April 2001 report similarly concluded that OASD (C3I) needed to provide
stronger oversight and better direction to DOD's adjudication facility
officials. After a review of DOD's personnel security investigations
program, an October 2002 report by the House Government Reform Committee
recommended, "The Secretary of Defense should continue to report the
personnel security investigations program

including the adjudicative process as a material [sic] weakness24 under
the Federal Managers' Financial Integrity Act to ensure needed oversight
is provided to effectively manage and monitor the personnel security
process from start to finish."25 DOD concurred with our October 1999
recommendation to declare its investigations program as a material
weakness to ensure that needed oversight is provided and that actions are
taken. For fiscal years 2000 through 2003, DOD listed the personnel
security program as a systemic weakness, which is a weakness that affects
more than one DOD component and may jeopardize the department's
operations.26

Delays in implementing the joint adjudication system, JPAS, have greatly
inhibited OUSD (I)'s ability to monitor overdue reinvestigations and
generate accurate estimates for that portion of the backlog. Among JPAS's
intended purposes are to consolidate DOD's security clearance data systems
and provide various levels of near real-time input and retrieval of
clearance-related information to OUSD (I), investigators, adjudicators,
and security officers at commands, agencies, and industrial facilities.
The DOD Chief Information Officer identified JPAS as a critical mission
system. When we reported on the reinvestigations backlog in August 2000,
the Assistant Secretary of Defense for Command, Control, Communications,
and Intelligence stated that JPAS would be fully implemented in fiscal
year 2001 and would be capable of providing recurring reports showing the
accurate number of cleared personnel requiring a periodic reinvestigation
by component and type of investigation. In early December 2003, an OUSD
(I) official said current plans are to have JPAS fully operational by
January 2004. The delays are caused by problems such as loading
adjudicative data from each central adjudication facility's internally
developed database and historical data from the Defense Clearance and
Investigation Index.

24 While the October 2002 House Committee on Government Reform report does
indeed make this recommendation, the DOD's annual statements of assurance
for fiscal year 2000 and for fiscal year 2001 and its annual performance
and accountability reports for fiscal year 2002 and for fiscal year 2003
report the personnel security investigations program as a "systemic
weakness." Committee on Government Reform report, Oct. 24, 2002.

25 Committee on Government Reform report, Oct. 24, 2002, p. 36.

26 Department of Defense Annual Statement of Assurance, Fiscal Year 2000
and Fiscal Year 2001; Department of Defense Performance and Accountability
Report, Fiscal Year 2002 (Jan. 31, 2003) and Fiscal Year 2003 (Dec. 23,
2003).

  Backlogs and Poor Estimates May Lead to Increased National Security Risks,
  Higher Costs, and Workload Uncertainties

DOD's failure to eliminate its backlog of overdue reinvestigations may
heighten the risk of national security breaches. Also, backlog-related
delays in issuing initial security clearances may raise the cost of doing
classified work for the U.S. government. In addition, DOD's inability to
accurately determine the actual size of its clearance backlog and project
the number of clearances needed results in inaccurate budget requests and
staffing plans.

    Continued Failure to Eliminate Backlog May Lead to Increased National
    Security Risks and Unnecessary Costs

Delays in completing reinvestigations caused by the backlog and other
impediments may lead to a heightened risk of national security breaches.
Such breaches involve the unauthorized disclosure of classified
information, which can have effects that range from exceptionally grave
damage to national security for top secret information to damage for
confidential information.27 In 1999, the Joint Security Commission
reported that delays in initiating reinvestigations create risks to
national security because the longer individuals hold clearances the more
likely they are to be working with critical information systems.28

Delays in completing initial security clearances may have an economic
impact on the cost of performing classified work within or for the U.S.
government. Although estimates of the total economic costs of delays in
granting clearances are dated, they reflect the extent of an ongoing
problem. In a 1981 report, we estimated that the DOD investigative backlog
could cost nearly $1 billion per year in lost productivity.29 More than a
decade later, the Joint Security Commission report noted that the costs
directly attributable to investigative delays in fiscal year 1994 could be
as high as several billion dollars because workers were unable to perform
their jobs while awaiting a clearance.30 While newer overall cost

27 Classification of National Security Information, 5 C.F.R. S:1312.4
(2003).

28 Joint Security Commission II, Report of the Joint Security Commission
II, (Aug. 24, 1999), p. 5-6.

29 U.S. General Accounting Office, Faster Processing of DOD Personnel
Security Clearances Could Avoid Millions in Losses, GAO/GGD-81-105
(Washington, D.C.: Sept. 15, 1981).

30 Joint Security Commission, Redefining Security: A Report to the
Secretary of Defense and the Director of Central Intelligence, Chapter 4,
Personnel Security-The First and Best Defense (Washington, D.C.: Feb. 28,
1994).

estimates are not available, the underlying reasons-the backlog and
clearance delays that prevent the employment-for the costs still exist
within DOD. For instance, DSS reported that the average time required to
complete an initial investigation for a top secret clearance was 454 days
for fiscal year 2002 and 257 days for October 2002 through February 2003.

The impact of delays in completing initial clearances affects industry,31
which relies on DOD to provide clearances for their employees.
Representatives from one company with $1 billion per year in sales stated
that their company offers a $10,000 bonus to its employees for each person
recruited who already has a security clearance. Such operating costs are
then passed on to government customers in the form of higher bids for
contracts. In turn, the recruit's former company may need to back-fill a
position, as well as possibly settle for a lower level of contract
performance while a new employee is found, obtains a clearance, and learns
the former employee's job. Also, industry representatives discussed
instances where their companies gave hiring preference to personnel who
could do the job but were less qualified than others who did not possess a
clearance. The chair of the interagency Personnel Security Working Group
noted that a company might hire an employee and begin paying that
individual, but not assign any work to the individual until a clearance is
obtained. Also, the head of the interagency group noted that commands,
agencies, and industry might incur lost-opportunity costs if the
individual chooses to work somewhere else rather than wait to get the
clearance before beginning work.

    Poor Estimates Can Result in Inadequate Budget and Staffing

DOD's inability to accurately project its personnel security clearance
workload requirements have created budgeting and staffing difficulties for
DOD units involved in the clearance process. For example, in fiscal year
2000, the services and defense agencies had to limit the number of overdue
reinvestigations that they submitted for investigation because they had
not budgeted the additional funds needed to cover the costs of the
increased workload. Differences between the targeted and actual number of
investigations for fiscal years 2001 to 2003 (see table 2) also document
problems with the current procedures used to project clearance
requirements. Inaccurate projections of personnel security clearance

31 We have an ongoing effort for the House Government Reform Committee
that is examining the backlog of industry requests for clearances, the
timeliness of clearance determinations, and the steps that DOD might take
to make its process more efficient.

  Status Update on the Authorized Transfer of DSS Investigative Functions and
  Personnel to OPM

workloads may have also caused the backlog to be bigger than it might
otherwise be because DSS and the central adjudication facilities did not
adequately plan for increases in workloads.

In December 2003, advisors to the Director of OPM recommended that the
congressionally authorized transfer of DSS investigative functions and
personnel to OPM not occur-at least for the rest of fiscal year 2004-due
primarily to concerns about the financial risks associated with the
transfer. The advisors recommended an alternative plan that is currently
being discussed by DOD and OPM officials. The alternative plan proposes
that DSS investigative functions and employees stay in DOD; use the OPM
case management system, which according to a DOD official would save about
$100 million in costs associated with continuing to update and maintain
DOD's current case management system; and receive training to use that
system from OPM. As of December 16, 2003, the Secretary of Defense had not
provided Congress with the certifications required before the transfer can
take place.

    Background of the Authorized Transfer

On February 3, 2003, a DOD news release announced that the Deputy
Secretary of Defense and the Director of the OPM had signed an agreement
that would allow DOD to divest its personnel security investigative
functions and OPM to offer positions to DSS investigative personnel. The
proposal for the transfer of functions and personnel was included in DOD's
The Defense Transformation for the 21st Century Act when that legislative
proposal was submitted to Congress on April 10, 2003. Also, the Secretary
of Defense's annual report to the President and to Congress for 2003 cited
the transfer as an effort to "[r]eengineer the personnel security program
by seeking statutory authority to transfer the personnel security
investigation function currently performed by the Defense Security Service
to the Office of Personnel Management, thus streamlining activities and
eliminate redundancy."32 The projected savings were estimated to be
approximately $160 million over the fiscal year 2004 to 2009 time frame.

On November 24, 2003, the National Defense Authorization Act for Fiscal
Year 2004 authorized the transfer of DSS's personnel security
investigative

32 Donald H. Rumsfeld, Secretary of Defense, Annual Report to the
President and to Congress 2003, p. 64.

functions and its 1,855 investigative employees to OPM.33 Before the
transfer can occur, the Secretary of Defense must certify in writing to
the House and Senate Armed Services Committees that the following five
conditions have been met:

o  	OPM is fully capable of carrying out high-priority investigations
required by the Secretary of Defense within a time frame set by the
Secretary of Defense;

o  	OPM has undertaken necessary and satisfactory steps to ensure that
investigations performed on DOD contract personnel will be conducted in an
expeditious manner sufficient to ensure that those contract personnel are
available to DOD within a time frame set by the Secretary of Defense;

o  	DOD will retain capabilities in the form of federal employees to
monitor and investigate DOD and contractor personnel as necessary to
perform counterintelligence functions and polygraph activities of the
department;

o  	The authority to adjudicate background investigations will remain with
DOD, and the transfer of DSS personnel to OPM will improve the speed and
efficiency of the adjudicative process; and

o  	DOD will retain within DSS sufficient personnel and capabilities to
improve DOD industrial security programs and practices.

The Director of OPM may accept the transfer, but such a transfer may be
made only after a period of 30 days has elapsed from the date on which the
defense committees receive the certification.

                   Current Status of the Authorized Transfer

Senior OPM officials recommended that the Director of OPM should not
accept the transfer of DSS's investigative functions and personnel, at
least for the rest of fiscal year 2004. The OPM officials reported that
OPM is not currently prepared to accept DSS's investigative functions and
staff because of concerns about financial risks associated with the
authorized transfer. OPM stated that under its current system of
contracting out all investigations, the contractor assumes all financial
risk for completing investigations at agreed-upon prices. OPM does not
believe that current productivity data for DSS staff is sufficient to
indicate whether DSS staff could provide the services at the price that
OPM charges its customers. Also, OPM believes that the documentation for
the financial costs of automobile leases, office space, and so forth are
not currently adequate to

33 Pub. L. 108-136 S: 906 (Nov. 24, 2003).

provide OPM with the assurance that it needs to accept 1,855 personnel
into an agency that currently has about 3,000 employees-more than a 60
percent growth in the number of OPM employees.

In a memorandum of understanding that is being finalized at OPM and DOD,
OPM is offering an alternative plan for DSS's investigative functions and
staff. While we were not provided a copy of the document, OPM officials
described its contents to us orally. Among other things, the plan-if
approved-would include the following:

o  DSS's investigative functions and staff would remain part of DOD;

o  	DSS's investigative staff would receive training from OPM on the use
of OPM's investigative procedures and OPM's investigations management
system; and

o  	OPM would allow DOD to use OPM's investigations management system and
thereby negate the need for DSS's investigations management system, which
an OUSD (I) official indicated could cost about $100 million to update and
maintain over the next 5 years.

A senior OPM official with whom we spoke was optimistic that the
alternative plan will go to DOD for review and signature before the end of
December 2003. If DOD proposes changes, the plan will need to undergo
re-staffing at OPM and possibly DOD. OPM's position described above was
verified with the same OPM official on December 16, 2003.

After learning of the alternative plan and the draft memorandum of
understanding, we discussed both with an OUSD (I) official who has been a
key negotiator with OPM. The official verified that OPM had voiced the
concerns regarding risk and was preparing an alternative plan. That DOD
official is optimistic that DOD will be able to provide the assurances
that are needed for the authorized transfer to occur before the end of
fiscal year 2004. DOD's position was verified with the same OUSD (I)
official on December 16, 2003.

Conclusions 	DOD continues to have a personnel security clearance backlog
that probably exceeds roughly 360,000 cases by some unknown number. This
situation may increase risks to national security and monetary costs
associated with delays in granting clearances. DOD faces many impediments
as it attempts to eliminate its backlog, and these weaknesses are material
to the prompt completion of clearance requests at all stages of the
personnel security process. The large number of clearance requests being
submitted may be the impediment that is least amenable to change.

As we mentioned earlier, worldwide deployments, contact with sensitive
equipment, and other security requirements underpin the need for personnel
to be cleared for access to classified information. Other impediments to
eliminating the backlog are formidable, but more tractable. Shortages of
investigative and adjudicative staff prevent DOD from quickly completing
cases in the existing backlog as well as the hundreds of thousands of new
clearance requests that have been submitted during each of the last 3
years. Using the rough estimates provided by an OPM official, the shortage
of over 3,500 full-time-equivalent investigative staff illustrates one
area in the clearance process where supply of personnel is inadequate to
meet the demand for services. DOD has not developed a strategic plan for
overcoming problems in accessing information locally, at the state level,
and overseas during investigations; and this lack of a strategy hinders
DOD efforts to quickly complete cases and efficiently eliminate the
clearance backlog.

Basic to designing an efficient means for overcoming the impediments is
obtaining and using accurate information regarding the backlog. Clear
pictures of the backlog size will continue to be elusive if components
continue to use varying backlog definitions and measures. The presence of
a backlog of an imprecise size and impediments throughout the clearance
process suggest systemic weaknesses in DOD's personnel security clearance
program. Key to generating those reports is the implementation of the
overdue JPAS with its ability to track when reinvestigations are due.

Because of continuing concerns about the size of the backlog and its
accurate measurement and the personnel security clearance program's
importance to national security, we recommend that the Secretary of
Defense direct the Under Secretary of Defense for Intelligence take the
following four actions:

o  	Identify and implement steps to match the sizes of the investigative
and adjudicative workforces to the clearance request workload;

o  	Develop a strategic plan for overcoming problems accessing data
locally, at the state level, and overseas;

o  	Develop DOD-wide backlog definitions and measures, and monitor the
backlog at each of the three clearance-process stages using the DOD-wide
measures; and

o  	Complete the implementation of the Joint Personnel Adjudication
System.

  Recommendations for Executive Action

  Agency Comments
  and Our Evaluation

In written comments on a draft of this report, OUSD (I) concurred with
three of our four recommendations and partially agreed with our
recommendation to match workforces with workload. OUSD (I) noted that (1)
DOD is developing tools to predict and validate investigative
requirements; (2) staffing, budgeting, and management of the investigative
and adjudicative resources are the purview of the affected DOD component
and investigative providers; and (3) growing a capable workforce takes
time. We agree with these points, but they do not change the fact that DOD
has historically had a backlog and that these issues must be dealt with
timely and effectively to eliminate the backlog. As our report points out,
implementation delays-such as that with JPAS-hamper efforts to accurately
estimate the backlog and eliminate it. While it is true that the resources
provided by DOD components play an important role in eliminating the
backlog, OUSD (I) also has a critical leadership role because of its
responsibility for the coordination and implementation of DOD policy for
accessing classified information. Finally, the historical and continuing
void between workload demand and capacity suggests that OUSD (I) needs to
take supplemental steps to grow capable investigative and adjudicative
workforces as we have recommended.

DOD's comments are reprinted in appendix III. DOD also provided technical
comments that we incorporated in the final draft as appropriate.

As arranged with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 15 days from
its issue date. At that time, we will send copies of this report to the
Secretary of Defense, the Office of Management and Budget, and the Office
of Personnel Management. We will also make copies available to appropriate
congressional committees and to other interested parties on request. In
addition, the report will be available at no charge at the GAO Web site at
http://www.gao.gov.

If you or your staff have questions about this report, please contact me
at
(202) 512-5559 or [email protected]. Key staff members contributing to
this report were Jack E. Edwards, Robert R. Poetta, Frank Bowen, and
Nancy L. Benco.

Sincerely yours,

Derek B. Stewart
Director, Defense Capabilities and Management

Appendix I: Recent Recommendations Related to DOD's Personnel Security Clearance
Process

This appendix lists the personnel clearance process recommendations found
in recent reports from GAO, the DOD Office of Inspector General, and the
House Committee on Government Reform. These verbatim recommendations are
arranged according to the issuance dates of the reports. At the end of
each set of recommendations, we provide comments on whether DOD concurred
with the recommendations and the rationale for nonconcurrences.

Recommendations from U.S. General Accounting Office, DOD Personnel:
Inadequate Personnel Security Investigations Pose National Security Risks,
GAO/NSIAD-00-12, Washington, D.C., October 27, 1999.

Because of the significant weaknesses in the DOD personnel security
investigation program and the program's importance to national security,
we recommend that the Secretary of Defense direct the Assistant Secretary
of Defense (Command, Control, Communications, and Intelligence) to

o  	report the personnel security investigation program as a material
weakness under the Federal Managers' Financial Integrity Act to ensure
that the needed oversight is provided and that actions are taken to
correct the systemic problems in the Defense Security Service personnel
security investigation program;

o  	improve its oversight of the Defense Security Service personnel
security investigation program, including approving a Defense Security
Service strategic plan; and

o  	identify and prioritize overdue reinvestigations, in coordination with
other DOD components, and fund and implement initiatives to conduct these
reinvestigations in a timely manner.

In addition, we recommend that the Secretary of Defense instruct the
Defense Security Service Director, with oversight by the Assistant
Secretary of Defense (Command, Control, Communications, and Intelligence)
to

o  	develop a corrective action plan as required under the Federal
Managers' Financial Integrity Act that incorporates corrective actions and
milestones for addressing material weaknesses in the Defense Security
Service personnel security investigative program and performance measures
for monitoring the progress of corrective actions;

Appendix I: Recent Recommendations Related to DOD's Personnel Security
Clearance Process

o  	establish a strategic plan that includes agency goals, performance
measures, and procedures for tracking progress in meeting goals in
accordance with sound management practices and the Government Performance
and Results Act;

o  	conduct analyses needed to (1) determine an appropriate workload that
investigators and case analysts can manage while meeting federal standards
and (2) develop an overall strategy and resource plan to improve the
quality and timeliness of investigations and reduce the number of overdue
reinvestigations;

o  	review and clarify all investigative policy guidance to ensure that
investigations comply with federal standards;

o  	establish a process for identifying and forwarding to the Security
Policy Board suggested changes to policy guidance concerning the
implementation of the federal standards and other investigative policy
issues;

o  	establish formal quality control mechanisms to ensure that Defense
Security Service or contracted investigators perform high-quality
investigations, including periodic reviews of samples of completed
investigations and feedback on problems to senior managers, investigators,
and trainers;

o  	establish a training infrastructure for basic and continuing
investigator and case analyst training that includes formal feedback
mechanisms to assess training needs and measure effectiveness, and as a
high priority, provide training on complying with federal investigative
standards for investigators and case analysts; and

o  	take steps to correct the case management automation problems to gain
short-term capability and develop long-term, cost-effective automation
alternatives.

Further, we recommend that the Secretary direct all DOD adjudication
facility officials to (1) grant clearances only when all essential
investigative work has been done and (2) regularly communicate with the
Defense Security Service about continuing investigative weaknesses and
needed corrective actions.

DOD concurred with all of the recommendations and described many actions
already planned or underway to implement the recommendations.

Recommendations from U.S. General Accounting Office, More Actions Needed
to Address Backlog of Security Clearance Reinvestigations,
GAO/NSIAD-00-215, Washington, D.C., August 24, 2000.

Appendix I: Recent Recommendations Related to DOD's Personnel Security
Clearance Process

To improve the management of DOD's personnel security reinvestigation
program, we recommend that the Secretary of Defense direct the Assistant
Secretary of Defense (Command, Control, Communications, and Intelligence)
to

o  	design routine reports with key data from the Joint Personnel
Adjudication System database to show the full extent of overdue
reinvestigations, including those overdue but not yet submitted for update
and those in process and

o  	develop appropriate incentives to encourage agency security managers
to keep information in the database current and to submit reinvestigation
requests on time. Changes in existing regulations, policies, and
procedures may be necessary to provide such incentives.

DOD concurred with all of the recommendations. In their comments, DOD
stated that those personnel who have not had a request for their periodic
reinvestigation submitted to the Office of Personnel Management or the
Defense Security Service by September 30, 2002, would have their security
clearances downgraded or canceled.

Recommendations from Department of Defense, Office of Inspector General
Audit Report, Security Clearance Investigative Priorities, Report No.
D-2000-111, Arlington, Va., April 5, 2000.

o  	We recommend that the Assistant Secretary of Defense (Command,
Control, Communications, and Intelligence) establish an Integrated Process
Team to

o  	Develop criteria for determining the highest priority mission-critical
and high-risk positions based on their impact on mission-critical
programs. The criteria must also include a review of the special projects
at the Defense Security Service.

o  	Develop a process for relating specific clearance requests to
mission-critical and high-risk positions. This process must identify
specific individuals as they are submitted for initial investigations and
periodic reinvestigations. The process should continually adjust the
highest priority mission-critical and high-risk positions to actions that
may impact them.

o  	We recommend that the Director, Defense Security Service, establish
the process and metrics to ensure expeditious processing of personnel
security clearance investigations in accordance with established
priorities.

Appendix I: Recent Recommendations Related to DOD's Personnel Security
Clearance Process

The Assistant Secretary of Defense (Command, Control, Communications, and
Intelligence) non-concurred with the first recommendation, stating that
the recommendations are beyond the scope and ability of his Office to
implement, especially in the near future. However, the Defense Security
Service concurred with the intent of the recommendation.

DOD and DSS concurred with the second recommendation.

Recommendations from U.S. General Accounting Office, DOD Personnel: More
Consistency Needed in Determining Eligibility for Top Secret Security
Clearances, GAO/NSIAD-01-465, Washington, D.C., April 18, 2001.1

To provide better direction to DOD's adjudication facility officials,
improve DOD's oversight, and enhance the effectiveness of the adjudicative
process, GAO recommends that the Secretary of Defense direct the Assistant
Secretary of Defense (Command, Control, Communications, and Intelligence)
to

o  	establish detailed documentation requirements to support adjudication
decisions, including all significant adverse security conditions and the
mitigating factors relevant to each condition;

o  	require that all DOD adjudicators use common explanatory guidance,
such as that contained in the Adjudicative Desk Reference;

o  	establish common adjudicator training requirements and work with the
Defense Security Service Academy to develop appropriate continuing
education opportunities for all DOD adjudicators; and

o  	establish a common quality assurance program to be implemented by
officials in all DOD adjudication facilities and monitor compliance
through annual reporting.

DOD concurred with all of the recommendations and described the actions it
planned to take to improve its guidance, training, and quality assurance
program.

1 The recommendations from this report on DOD adjudication were included
because (1) the adjudications rely heavily on high-quality, complete
personnel security investigations and (2) the 2002 House Committee on
Government Reform report recommended including the adjudicative portion of
the clearance process as a material weakness.

Appendix I: Recent Recommendations Related to DOD's Personnel Security
Clearance Process

Recommendations from Department of Defense, Office of Inspector General
Audit Report, Tracking Security Clearance Requests, Report No. D-2000-134,
Arlington, Va., May 30, 2000.

o  	We recommend that the Director, Defense Security Service, track all
security clearance requests from the time they are received until the
investigative cases are opened. Security clearance requests that are not
opened to investigative cases, and those investigative cases that are
opened without electronic requests should be included in the tracking
process.

o  	Post, weekly, the names and social security numbers of all cases in
process on the Extranet for Security Professionals. This entry for each
name should include, at a minimum, the date that the request was loaded
into the Case Control Management System, the date that the investigative
case was opened, and the date that the case was closed.

DOD and DSS concurred on these recommendations.

Recommendation from Department of Defense, Office of Inspector General
Audit Report, Program Management of the Defense Security Service Case
Control Management System, Report No. D-2001-019, Arlington, Va., December
15, 2000.

We recommend that the Assistant Secretary of Defense (Command, Control,
Communications, and Intelligence) and the Director, Defense Security
Service, prior to making further decisions on the future system
architecture, analyze whether the investment for the Case Control
Management System and the Enterprise System provides the best business
solution when compared to alternative solutions for opening, tracking and
closing personnel investigation cases.

DOD and DSS concurred with this recommendation.

Recommendations from U.S. House of Representatives, Committee on
Government Reform, Defense Security Service: The Personnel Security
Investigations [PSI] Backlog Poses a Threat to National Security, Report
107-767, Washington, D.C., October 24, 2002.

o  	The Secretary of Defense should continue to report the personnel
security investigations program including the adjudicative process as a
material weakness under the Federal Managers' Financial Integrity Act

Appendix I: Recent Recommendations Related to DOD's Personnel Security
Clearance Process

to ensure needed oversight is provided to effectively manage and monitor
the personnel security process from start to finish.

o  	The Secretary of Defense should set priorities and control the flow of
personnel security investigation requests for all DOD components.

o  	The Secretary of Defense should closely monitor the interface between
JPAS and CCMS to ensure effective management of investigative and
adjudicative cases and avoid further backlogs.

o  	The National Security Council should promulgate Federal standards for
investigating and adjudicating personnel security clearances in a timely
manner.

o  	The Secretary of Defense and the Attorney General jointly should
develop a system, which allows DSS and OPM investigators access to state
and local criminal history information records.

DOD indicated that it does not plan to respond to these recommendations.

                       Appendix II: Scope and Methodology

To estimate the size and accuracy of the Department of Defense-wide (DOD)
personnel security clearance backlog, we obtained separate estimates of
the investigative and adjudicative backlogs from the Defense Security
Service (DSS), the Office of Personnel Management (OPM), and DOD's central
adjudication facilities. Also, we obtained some DOD-wide information from
the Office of the Under Secretary of Defense for Intelligence (OUSD (I)).
As part of the estimation process, we observed the steps used to capture
and process investigative information at DSS and OPM. We obtained
additional information regarding issues such as number of days required to
complete an investigation or adjudication, time limits (i.e., criteria)
for completing investigations and adjudications, and data reliability from
DSS, OPM, and the central adjudication facilities during site visits,
through questionnaires, and by interviews. We conducted this work at OUSD
(I), Washington, D.C.; DSS, Fort Meade, Maryland; OPM, Washington, D.C.,
and Boyers, Pennsylvania; Army, Navy, Air Force, National Security Agency,
Defense Intelligence Agency, Joint Staff, and Washington Headquarters
Services central adjudication facilities located in the Washington, D.C.,
metropolitan area; the Defense Industrial Security Clearance Office,
Columbus, Ohio; and the Defense Office of Hearings and Appeals, Arlington,
Virginia, and Columbus, Ohio. We did not request data from the National
Reconnaissance Office central adjudication facility because of the
sensitive nature of its operations. Reviews of GAO, House Government
Reform Committee, and Joint Security Commission reports provided a
historical perspective for the report. Additional context for
understanding DOD's personnel security program was obtained through a
review of DOD regulations (e.g., DOD 5200.2-R), federal investigative
standards, and federal adjudicative guidelines.

To identify the factors that impede DOD's ability to eliminate its backlog
and accurately estimate the backlog size, we reviewed prior GAO, DOD
Office of Inspector General, House Government Reform Committee, Defense
Personnel Security Research Center, and Joint Security Commission reports.
DSS and OPM provided procedural manuals and discussed impediments while
demonstrating their automated case management systems and provided other
information such as workload data in responses to written questions and in
interviews. Interviews regarding impediments were also held with officials
from OUSD (I); nine central adjudication facilities; the Defense Personnel
Security Research Center; the Chair of the Personnel Security Working
Group of the National Security Council, Washington, D.C.; investigations
contractors at their

Appendix II: Scope and Methodology

headquarters: US Investigations Services, Inc.; ManTech; and DynCorp; and
associations representing industry:1 Aerospace Industries Association,
Information Technology Association of America, National Defense Industrial
Association, and Northern Virginia Technology Council. Our General
Counsel's office supplied additional context for evaluating potential
impediments through its review of items such as the Security Clearance
Information Act and Executive Order 12968, Access to Classified
Information.

To identify the potential adverse effects of the impediments to
eliminating the backlog and accurately estimating its size, we reviewed
prior GAO and Joint Security Commission reports. We supplemented this
information with recent data from DSS and OPM regarding the number of days
that it took to complete various types of investigations. Also, an
interview with the Chair of the Personnel Security Working Group of the
National Security Council provided a governmentwide perspective on the
effects of delays and backlogs. Industry representatives cited above
provided other perspectives on the economic costs of delays in obtaining
eligibility-forclearance determinations.

For our update on the status of the authorized transfer of DSS's
investigative functions and staff to OPM, we reviewed the National Defense
Authorization Act for Fiscal Year 2004 and GAO reports on DSS and OPM
operations. In addition, we reviewed planning documents such as those
describing the various transfer-related action teams that OPM and DOD
created; these teams included one that sought to reconcile differences in
the procedures used to conduct personnel security investigations. We also
conducted interviews in December with DOD and

1 Information from industry associations was obtained as part of an
ongoing GAO engagement examining DOD's personnel security clearance
process as it applies to industry personnel. More specifically, the
engagement examined the size of the backlog, timeliness of
eligibility-for-clearance decisions, and steps that DOD is taking to
decrease the time required for those decisions.

Appendix II: Scope and Methodology

OPM to determine up-to-date perspectives regarding the authorized transfer
from officials representing both agencies.

We conducted our review from February 2003 through December 2003 in
accordance with generally accepted government auditing standards.

Appendix III: Comments from the Department of Defense

Appendix III: Comments from the Department of Defense

Appendix III: Comments from the Department of Defense

Note: Page numbers in the draft report may differ from those in this
report.

Appendix III: Comments from the Department of Defense

                       Appendix IV: Related GAO Products

DOD Personnel: More Consistency Needed in Determining Eligibility for Top
Secret Clearances. GAO-01-465. Washington, D.C.: April 18, 2001.

DOD Personnel: More Accurate Estimate of Overdue Security Clearance
Reinvestigation Is Needed. GAO/T-NSIAD-00-246. Washington, D.C.: September
20, 2000.

DOD Personnel: More Actions Needed to Address Backlog of Security
Clearance Reinvestigations. GAO/NSIAD-00-215. Washington, D.C.: August 24,
2000.

DOD Personnel: Weaknesses in Security Investigation Program Are Being
Addressed. GAO/T-NSIAD-00-148. Washington, D.C.: April 6, 2000.

DOD Personnel: Inadequate Personnel Security Investigations Pose National
Security Risks. GAO/T-NSIAD-00-65. Washington, D.C.: February 16, 2000.

DOD Personnel: Inadequate Personnel Security Investigations Pose National
Security Risks. GAO/NSIAD-00-12. Washington, D.C.: October 27, 1999.

Military Recruiting: New Initiatives Could Improve Criminal History
Screening. GAO/NSIAD-99-53. Washington, D.C.: February 23, 1999.

Background Investigations: Program Deficiencies May Lead DEA to Relinquish
Its Authority to OPM. GAO/GGD-99-173. Washington, D.C.: September 7, 1999.

Executive Office of the President: Procedures for Acquiring Access to and
Safeguarding Intelligence Information. GAO/NSIAD-98-245. Washington, D.C.:
September 1998.

Privatization of OPM's Investigations Service. GAO/GGD-96-97R. Washington,
D.C.: August 22, 1996.

Cost Analysis: Privatizing OPM Investigations. GAO/GGD-96-121R.
Washington, D.C.: July 5, 1996.

Personnel Security: Pass and Security Clearance Data for the Executive
Office of the President. GAO/NSIAD-96-20. Washington, D.C.: October 19,
1995.

Appendix IV: Related GAO Products

Privatizing OPM Investigations: Perspectives on OPM's Role in Background
Investigations. GAO/T-GGD-95-185. Washington, D.C.: June 14, 1995.

Background Investigations: Impediments to Consolidating Investigations and
Adjudicative Functions. GAO/NSIAD-95-101. Washington, D.C.: March 24,
1995.

Security Clearances: Consideration of Sexual Orientation in the Clearance
Process. GAO/NSIAD-95-21. Washington, D.C.: March 24, 1995.

Personnel Security Investigations: GAO/NSIAD-94-135R. Washington, D.C.:
March 4, 1994.

Nuclear Security: DOE's Progress on Reducing Its Security Clearance Work
Load. GAO/RCED-93-183. Washington, D.C.: Aug. 12, 1993.

DOD Special Access Programs: Administrative Due Process Not Provided When
Access is Denied or Revoked. GAO/NSIAD-93-162. Washington, D.C.: May 5,
1993.

Personnel Security: Efforts by DOD and DOE to Eliminate Duplicative
Background Investigations. GAO/RCED-93-23. Washington, D.C.: May 10, 1993.

Administrative Due Process: Denials and Revocations of Security Clearances
and Access to Special Programs. GAO/T-NSIAD-93-14. Washington, D.C.: May
5, 1993.

Security Clearances: Due Process for Denials and Revocations by Defense,
Energy, and State. GAO/NSIAD-92-99. Washington, D.C.: May 6, 1992.

Due Process: Procedures for Unfavorable Suitability and Security Clearance
Actions. GAO/NSIAD-90-97FS. Washington, D.C.: April 23, 1990.

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