DOD Personnel Clearances: Government Plan Addresses Some
Longstanding Problems with DOD's Program, But Concerns Remain
(09-NOV-05, GAO-06-233T).
Unauthorized disclosure of classified information can cause up to
exceptionally grave damage to national security. The Department
of Defense (DOD) is responsible for about 2 million personnel
with clearances that allow them access to classified information.
While most of these clearances are for servicemembers and DOD's
employees and contractors, DOD is also responsible for
contractors' clearances for more than 20 other agencies, as well
as for congressional staff. Due to long-standing problems with
DOD's clearance program, GAO designated it a high-risk area in
January 2005. In February 2005, when DOD transferred its
personnel security investigative functions to the Office of
Personnel Management (OPM), the average wait for a top secret
clearance governmentwide was over 1 year. In June 2005, Executive
Order 13381 gave the Office of Management and Budget (OMB)
authority to retain or assign to any executive agency any process
relating to determinations of eligibility for access to
classified information. OPM is assisting OMB with the development
of the plan. GAO was asked to assess the government plan. This
testimony will provide GAO's preliminary review of how well the
government plan (1) adheres to the standards of comprehensive
strategic planning and (2) addresses the timeliness and quality
of the security clearance process. Finally, GAO will discuss the
actions required to remove DOD's program from GAO's high-risk
list.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-06-233T
ACCNO: A41257
TITLE: DOD Personnel Clearances: Government Plan Addresses Some
Longstanding Problems with DOD's Program, But Concerns Remain
DATE: 11/09/2005
SUBJECT: Background investigations
Classified defense information
Eligibility determinations
Homeland security
Internal controls
National security personnel system
Performance measures
Personnel security clearance programs
Policy evaluation
Quality assurance
Security clearances
Strategic planning
Timeliness
******************************************************************
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GAO-06-233T
Chairman Voinovich and Members of the Subcommittee:
I am pleased to be here today to discuss the government plan for
addressing problems in the Department of Defense's (DOD) personnel
security clearance program. Clearances granted through such programs allow
personnel access to classified information. Unauthorized disclosure of
classified information can cause exceptionally grave damage to national
security. As you know, Mr. Chairman, in January of this year, we added
DOD's personnel security clearance program to our list of government
high-risk operations.1 Our high-risk list focuses on those major programs
and operations that need urgent attention and transformation in order to
ensure that our national government functions in the most economical,
efficient, and effective manner possible. Also, some federal programs and
operations are designated high risk because of their greater
vulnerabilities to fraud, waste, abuse, and mismanagement.
We declared DOD's personnel security clearance program a high-risk area in
January 2005, in part because of long-standing delays in completing
requests for security clearances. We have reported backlogs and
impediments to timeliness and quality throughout DOD's personnel security
clearance process. DOD has faced challenges in the past in setting and
projecting the requirements for clearances, submitting requests for
investigations, conducting timely investigations, and adjudicating, or
determining, whether someone is eligible for a clearance. We also found
that DOD had been unable to accurately estimate the size of its clearance
backlog.
Problems with timeliness and quality in the personnel security clearance
process can affect our national security. For example, delays in renewing
security clearances for personnel who are already doing classified work
can lead to a heightened risk of disclosure of classified information.
Moreover, delays in providing initial security clearances for previously
noncleared personnel can result in other negative consequences, such as
additional costs and delays in completing national security-related
contracts, lost-opportunity costs, and problems retaining the
best-qualified personnel. Given the vast scope of DOD's personnel security
clearance program, these negative effects resound across government.
Within DOD, the Office of the Under Secretary of Defense for Intelligence
is responsible for the clearances issued to approximately 2 million
personnel and for coordinating and implementing DOD-wide policies related
to accessing classified information. While most of the clearances DOD
handles are for servicemembers and DOD's federal employees and contractor
personnel, the Office of the Under Secretary for Intelligence is also
responsible for the clearances of contractors for more than 20 other
federal agencies, as well as the clearances of staff in the federal
government's legislative branch.
My testimony today will focus on the government plan and its relevance to
improving DOD's personnel security clearance process and how well it
addresses our past concerns. The Office of Management and Budget (OMB)
took the lead in developing the government plan, and the Office of
Personnel Management (OPM), which is now responsible for 90 percent of the
clearance investigations in the federal government, assisted OMB in
developing this plan. Because we have had a limited time to review the
government plan, we have been unable to conduct a thorough assessment.
Therefore, my preliminary observations will focus on four key areas.
First, I will describe how well the government plan adheres to the
standards of comprehensive strategic planning. Next, I will provide our
evaluation of how well the plan addresses concerns about the timeliness
and the quality of personnel security clearances. Finally, I will discuss
the actions required to remove the program from our high-risk list. I
would like to note that, at your request, we have recently begun a review
focusing on the quality of top secret security clearance investigations
and adjudications for contractor personnel. As of February 2005, these
personnel waited, on average, over 1 year for DOD to determine clearance
eligibility. As part of that review, we will examine the government plan
more fully and provide an assessment in our report to the Subcommittee.
1 See GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.:
January 2005).
My statement is based on our preliminary review of the government plan and
previous GAO reports and analyses. Our work was performed from October
2005 through November 2005 in accordance with generally accepted
government auditing standards. In our preliminary review, we considered
what was presented in the government plan in light of elements from the
Intelligence Reform and Terrorism Prevention Act of 2004 as well as
relevant prior reports from GAO and DOD's Inspector General.
Summary
In summary, Mr. Chairman, the government plan represents an important step
toward addressing some of the long-standing concerns we have raised about
the personnel security clearance process. We are encouraged by the high
level of commitment that OMB has demonstrated in preparing this plan. The
government plan provides many metrics that will be used to monitor the
timeliness of the clearance process governmentwide, but it provides few
details on other elements that a comprehensive strategic plan might
contain. For example, in some cases, the plan does not provide details on
discrete actions the government would take or projected completion dates
for actions the plan identifies. In addition, the plan does not always
include details on the resources required to accomplish the plan's
objectives. Finally, the plan does not describe potential risks or
mitigation plans to address potential risks.
The government plan identifies a wide variety of metrics for monitoring
the timeliness of security clearances. Passage of the Intelligence Reform
and Terrorism Prevention Act of 2004 addressed many of our past concerns
about metrics and monitoring the program. For example, the act requires
that, during the period between December 17, 2006, and December 17, 2009,
each authorized adjudicative agency shall make a determination on at least
80 percent of all applications for personnel security clearances within an
average of 120 days of receiving the security clearance request. However,
the government plan is inconsistent in its treatment of some timeliness
issues. Specifically, the plan provides quarterly goals for different
types of investigations, but it does not identify interim goals for
average adjudication processing time. In addition to metrics, the
government plan describes the use of information technology to positively
affect the timeliness of clearances.
The government plan devotes little attention to monitoring and improving
the quality of the personnel security clearance process, although it
explicitly acknowledges that agencies have concerns about the quality of
investigations and adjudications. The primary metric found in the
government plan for measuring the quality of investigations is the
percentage of investigations returned by requesting agencies because of
incomplete case files. Because the number of investigations returned for
rework is not-by itself-a valid indicator of the quality of investigative
work, use of other or additional statistics such as the number of
counterintelligence leads generated from investigations may be needed. The
government plan did not identify a metric for assessing the quality of
adjudications, although we and other agencies have identified actions that
would facilitate monitoring and improvement of the quality of this portion
of the security clearance process. However, the government plan contains
provisions for an investigator training and quality assurance program.
Before removing the security clearance process from our high-risk list, we
will examine whether OMB, OPM, and DOD have satisfied the criteria we have
established for removing a high-risk designation. As we established in
November 2000, these criteria include leadership support, sufficient
resources to resolve the risk, and a corrective action plan. Our criteria
also include the presence of a program to monitor and independently
validate the effectiveness and sustainability of any corrective actions
and the ability to demonstrate the implementation of corrective measures.
DOD must undertake many corrective actions to implement our
recommendations and to correct previously identified problems before its
personnel security clearance program can be removed from its high-risk
list.
Background
On June 28, 2005, I testified before this subcommittee on DOD's personnel
security clearance program.2 I noted that while DOD has taken steps to
address some of the problems that led us to designate its personnel
security clearance program a high-risk area, we found continuing
challenges in each stage of DOD's clearance process. I also noted that,
despite partially concurring with our May 2004 recommendation,3 DOD had
not developed and implemented an integrated, comprehensive management plan
to eliminate the backlog, reduce the delays in conducting investigations
and determining eligibility for security clearances, and overcome the
impediments that could allow such problems to recur.
On the day before your June hearing, the President signed Executive Order
13381, which is to expire on July 1, 2006, and has the stated purpose of
strengthening processes for determining eligibility for access to
classified national security information.4 The order stated that the
Director of OMB may assign, in whole or in part, to the head of any
agency, either solely or jointly, any process relating to determinations
of eligibility for access to classified national security information.
2 GAO, DOD Personnel Clearances: Some Progress Has Been Made but Hurdles
Remain to Overcome the Challenges That Led to GAO's High-Risk Designation,
GAO-05-842T (Washington, D.C.: June 28, 2005).
3 GAO, DOD Personnel Clearances: Additional Steps Can Be Taken to Reduce
Backlogs and Delays in Determining Security Clearance Eligibility for
Industry Personnel, GAO-04-632 (Washington, D.C.: May 26, 2004).
At the request of the OMB Deputy Director, OMB and GAO officials met on
July 12, 2005, to discuss OMB's general strategy for addressing the
problems that had led to our high-risk designation for DOD's personnel
security clearance program. Among other things, the Deputy Director
indicated that (1) OMB staff would work with DOD and OPM to develop
preliminary milestones and metrics for correcting problems associated with
the program and (2) GAO would be asked to comment on that information in
August or September. We indicated that GAO would need to remain
independent, but could provide general comments to OMB about milestones,
timeframes, criteria, and other materials developed by OMB and other
executive branch agencies. The timeframe of August or September for the
next meeting with OMB corresponded roughly with the up to 90 days after
selection that was specified in the Intelligence Reform and Terrorism
Prevention Act of 2004 for the head of the identified lead agency to
develop, in consultation with the appropriate committees of Congress and
each authorized adjudicative agency, a plan to reduce the length of the
personnel security clearance process.5
Plan Identifies Metrics but Lacks Details on Other Critical Elements of a
Strategic Plan
The government plan provides many metrics that will be used to monitor the
timeliness of the clearance process governmentwide, but the plan detailed
few of the other elements that a comprehensive strategic plan might
contain. The Government Performance and Results Act of 19936 identified
some of the elements that might be found in a comprehensive strategic
plan. Those elements include a comprehensive mission statement, general
goals and objectives, a description of how the goals and objectives are to
be achieved, key external factors that could significantly affect the
achievement of the goals and objectives, and a description and schedule of
the program evaluations used in establishing and revising general goals
and objectives. GAO has also published an evaluator's guide to use in
evaluating strategic plans. This guide discusses key performance
indicators and the means to verify and validate the measured values.7
The government plan provides numerous metrics to monitor the timeliness of
the clearance process. For example, the plan requires more accurate
projections of the numbers of clearances needed, statistics on how long it
takes to process a request for the investigation once the request has been
made, information on the time required to perform various types of
investigations, and the amount of time needed to determine clearance
eligibility. Many of the metrics will be monitored on a quarterly or
yearly basis according to the example tables contained in the plan.
Another positive feature of the plan is that the same metrics will be used
in many governmental agencies, making it possible to roll the data up and
obtain a larger federal government perspective.
4 The White House, Executive Order 13381, Strengthening Processes Relating
to Determining Eligibility for Access to Classified National Security
Information (June 27, 2005).
5 50 U.S.C. S: 435b(g).
6 Pub. L. No. 103-62.
7 GAO, The Results Act: An Evaluator's Guide to Assessing Agency Annual
Performance Plans, GAO/GGD-10.1.20 (Washington, D.C.: Apr. 1, 1998).
Many portions of the government plan fail to include important elements of
strategic planning that could influence how effectively and efficiently
the plan is carried out. I will illustrate our concerns using two example
sections from the plan. In the first case, the plan includes a section on
how the government intends to address reciprocity.8 For those who are
unfamiliar with that term, reciprocity is the extent to which departments,
agencies, or military services accept clearances and access granted by
other departments, agencies, or military services. The government plan
does not include discrete actions with projected completion dates that
could be used to monitor interim progress toward the goal of greater
reciprocity. The plan overlooks such actions and related timeframes even
though a June 17, 2005, memorandum written by the Deputy Director of OMB
indicates that the plan for each of the 25 areas on GAO's high-risk list
should set goals and milestones that, if implemented will reduce the risk
of waste, fraud, abuse, and mismanagement. A second example of the
security clearance plan's failure to follow principles of strategic
planning can be found in the plan's section on requirements for access to
national, state, and local record systems. Nothing in this section of the
plan mentions actions and milestones for actions, or how OMB or the
federal government could affect access to state and local records. The
plan also fails to consider whether additional monetary or human capital
resources would be needed for that effort, what external risks could
adversely affect the government plan, or what steps the government could
use to mitigate those risks.
Plan Emphasizes Timeliness of the Clearance Process
The government plan identifies a wide variety of metrics that can be used
to track the timeliness of clearances, and it describes generally some
initiatives for speeding the processing of clearances. In February 2004,
we expressed continuing concerns about the size of DOD's backlog and its
accurate measurement.9 At that time, we recommended that the Under
Secretary of Defense for Intelligence develop timeliness definitions and
measures, and monitor the security clearance backlog at each stage of the
personnel security clearance process.
8 50 U.S.C. S: 435b(d)(1) provides that "all security clearance background
investigations and determinations completed by an authorized investigative
agency or authorized adjudicative agency shall be accepted by all
agencies." Exceptions to reciprocity are, however, permitted on a
case-by-case basis under the conditions specified in the U.S. Code.
9 GAO, DOD Personnel Clearances: DOD Needs to Overcome Impediments to
Eliminating Backlog and Determining Its Size, GAO-04-344 (Washington,
D.C.: Feb. 9, 2004).
Passage of the Intelligence Reform and Terrorism Prevention Act of 2004
addressed our concerns about metrics and monitoring within the larger
context of the total federal government, specifying timeframes for the
completion of both investigations and adjudications and requiring an
annual report to Congress detailing the timeliness of the clearance
process. Specifically, the act requires that not later than December 17,
2006, and ending December 17, 2009, each authorized adjudicative agency
shall make a determination on at least 80 percent of all applicants for
personnel security clearances within an average of 120 days-90 days to
complete the investigation and 30 days to complete the adjudication-of
receiving the security clearance application.10 Also, not later than
February 15, 2006, and annually thereafter through 2011, OMB must provide
a report to appropriate congressional committees on the progress made
during the preceding year toward meeting these goals.11
The government plan identifies numerous management reports and metrics
that can be used to monitor all stages of the personnel security clearance
process. To monitor the submission of requests for investigations, the
plan indicates that the government will require that submissions be
processed within an average of 14 calendar days of the subject completing
the security clearance questionnaire. For the investigation stage, the
plan shows baseline measures for how long it took to complete the average
investigation and the investigative workload. This type of information is
shown for multiple quarters in fiscal year 2005. The plan also provides
quarterly goals-expressed as average days taken to complete an
investigation-for different types of investigations. The
adjudication-timeliness goals mandated by the National Intelligence Reform
and Terrorism Prevention Act of 2004 are noted in the plan, but it does
not identify baseline measures or interim goals for average adjudication
processing time.
In addition to metrics, the government plan describes the use of
information technology to positively affect the timeliness of clearances.
For example, OPM has deployed the electronic Questionnaire for
Investigations Processing (e-QIP) system for a subgroup of users and
indicates that all agencies will be required to submit their requests for
investigations with e-QIP by March 2006. OPM is also involved in an effort
to streamline clearance processing by digitally sending completed
investigation files to adjudicative agencies for review, approval, and
submission to the investigation provider. However, the plan provides few
details that would allow us to assess the maturity of either initiative.
Plan Needs to Build More Quality into the Clearance Process
The government plan devotes little attention to monitoring and improving
the quality of the personnel security clearance process. At the same time,
the government plan explicitly acknowledges that agencies have concerns
about the quality of investigations and adjudications. Specifically, the
plan says that "a lack of reciprocity often arises due to reluctance of
the gaining activity to inherit accountability for what may be an
unacceptable risk due to poor quality investigations and/or
adjudications." These concerns exist despite the fact that since 1997, all
federal agencies have been subject to a common set of general personnel
security investigative standards and adjudicative guidelines for
determining whether service members, government employees, government
contractors, and others are eligible to receive security clearances.12
10 50 U.S.C. S: 435b(g)(3). Section (g)(2) also provides that the
timeframe for completing clearances will reduce further once 5 years have
elapsed from the enactment of the section. At that time, the section
indicates that to the extent practical, the plan shall require each
authorized adjudicative agency to make a determination on at least 90
percent of all applications for a personnel security clearance within an
average of 60 days-40 days to complete the investigation and 20 days to
complete the adjudication.
11 50 U.S.C. S: 435b(h).
The primary metric found in the government plan for measuring quality of
investigations is the percentage of investigations returned by requesting
agencies due to incomplete case files, but use of that metric is
problematic. In 1999, we reported that the number of investigations
returned for rework is not by itself a valid indicator of the quality of
investigative work, because adjudication officials said they were
reluctant to return incomplete investigations in anticipation of further
delays.13 Regardless of whether this metric remains a part of the plan,
developers of the plan may want to consider adding other indicators of the
quality of investigations, such as the number of counterintelligence leads
generated from security clearance investigations and forwarded to relevant
units. Our 1999 review of a random sample of investigations is another
example of a method that can be used to evaluate quality. This type of
periodic review could be performed by an office of the inspector general
or some other unit that is not affiliated with OPM's investigations
facility in order to insure the independence of the findings.
The government plan indicates that OPM has developed an investigator
training and quality assurance program. This is a positive step. Our prior
work has shown that investigation quality can be negatively affected when
investigators are insufficiently trained. However, the plan does not
discuss implementation of the training program or the metrics associated
with the quality assurance program.
The government plan does not identify a metric for assessing the quality
of adjudications. As the Defense Personnel Security Research Center has
noted, it is difficult to measure the degree to which adjudicative
standards are met.14 Nevertheless, GAO and other agencies have identified
actions that would facilitate monitoring and improvement of the quality of
this portion of the security clearance process. For example, a 2001 GAO
report recommended that DOD require adjudicators to use common explanatory
guidance and document adjudication determinations.15 In addition, a 1998
DOD Inspector General report suggested implementation of a peer review
program among DOD adjudication facilities.16
12 The White House, "Implementation of Executive Order 12968," Memorandum
(Washington, D. C.: Mar. 24, 1997). This memorandum approves the
adjudication guidelines, temporary eligibility standards, and
investigative standards required by Executive Order 12968, Access to
Classified Information (Aug. 2, 1995).
13 GAO, DOD Personnel: Inadequate Personnel Security Investigations Pose
National Security Risks, GAO/NSIAD-00-12 (Washington, D.C.: Oct. 27,
1999).
14 Ralph M. Carney, Joanne Marshall-Mies, Daniel G. Youpa, and Whitney B.
Helton-Fauth, Quality Assurance in Defense Adjudication: An Adjudicator
Workshop for Defining and Assessing Quality, PERSEREC TR 02-04 (Monterey,
Calif.: Defense Personnel Security Research Center, March 2003).
The government plan does not contain initiatives for improving
adjudication quality. We have, however, previously reported
recommendations for improving DOD's adjudication quality.17 In our 2001
report, we recommended that DOD make four major improvements to its
adjudicative process. First, DOD should establish detailed documentation
requirements to support adjudication decisions. Second, the department
should require that all DOD adjudicators use common explanatory guidance.
Third, it should establish common adjudicator training requirements and
develop appropriate continuing education opportunities for all DOD
adjudicators. Finally, DOD should establish a common quality assurance
program to be implemented by officials in all DOD adjudication facilities
and monitor compliance through annual reporting. DOD has indicated
progress on some of these initiatives such as professional adjudicator
certification and continuing education opportunities. The government plan
may be able to broaden the DOD initiatives to governmentwide actions for
improving adjudication quality.
Actions Required to Remove DOD's Clearance Program from the High-Risk List
DOD must undertake many corrective actions to implement our
recommendations and to correct previously identified problems before we
will remove DOD's personnel security clearance program from our high-risk
list. Many of the issues about timeliness and quality are being addressed
in actions that OMB and OPM will monitor as part of the government plan.
Those actions need to address the criteria that we use in determining
whether or not to remove a high-risk designation. These criteria, which we
defined in November 2000, are shown in Figure 1.18
15 GAO, DOD Personnel: More Consistency Needed in Determining Eligibility
for Top Secret Security Clearances, GAO-01-465 (Washington, D.C.: Apr. 18,
2001).
16 DOD Office of the Inspector General, Audit Report: Department of
Defense Adjudication Program, DoDIG 98-124 (Washington, D.C.: 1998).
17 GAO-01-465.
18 GAO-01-159SP.
Figure 1: Criteria Agencies Must Meet Before High-Risk Designations Can Be
Removed
o A demonstrated strong commitment and top leadership support to
address the risk(s)
o The capacity (that is, the people and other resources) to resolve
the risk(s)
o A corrective action plan(s) that
o defines the root causes,
o identifies effective solutions, and
o provides for substantially completing corrective measures in
the near term, including but not limited to steps necessary to
implement solutions we recommend
o A program instituted to monitor and independently validate the
effectiveness and sustainability of corrective actions
o The ability to demonstrate progress in having implemented corrective
measures
Source: GAO.
Since our high-risk list began in 1990, the government has taken high-risk
problems seriously and has made long-needed progress toward correcting
them. During the past 15 years, those efforts have resulted in 16
high-risk areas being removed from the list. For example, in January 2005,
sufficient progress had been made to warrant the removal of a high-risk
designation from three areas: student financial aid programs, Federal
Aviation Administration financial management, and Forest Service financial
management.
We will remove a high-risk designation when agency actions, including
those in response to our recommendations, result in significant progress
toward resolving a high-risk problem.
- - - - -
Concluding Observations
Mr. Chairman, we are encouraged that OMB has undertaken the development of
a governmentwide plan for improving the personnel security clearance
process. Still, much remains to be done to develop a more comprehensive
plan for improving the timeliness and quality of the security clearance
process. Developing specific steps to address the general concerns that I
identified today should move OMB and the executive branch agencies closer
to that goal. As we stated in our high-risk report, perseverance by OMB
and the agencies to implement our prior recommendations and continued
oversight, such as that shown by you and this committee, are both
essential to bringing lasting solutions to this high-risk area. In short,
this is a good first step in the right direction. We will continue to
monitor the security clearance program, as we do for all of the programs
on our high-risk list.
Mr. Chairman and Members of the Subcommittee, this concludes my prepared
statement. I would be happy to answer any questions you may have at this
time.
Staff Contact and Acknowledgments
For further information regarding this testimony, please contact me at
202-512-5559 or stewartd@gao.gov. Individuals making key contributions to
this testimony include Jack E. Edwards, Assistant Director; Kurt A.
Burgeson; Susan C. Ditto; Sara Hackley; Kenneth E. Patton; William J.
Rigazio; and Jennifer L. Young.
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Screening. GAO/NSIAD-99-53 . Washington, D.C.: February 23, 1999.
Executive Office of the President: Procedures for Acquiring Access to and
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(350778)
United States Government Accountability Office
GAO
Testimony
Before the Subcommittee on Oversight of Government Management, the Federal
Workforce, and the District of Columbia, Committee on Homeland Security
and Governmental Affairs, U.S. Senate
For Release on Delivery
Expected at 3:00 p.m. Wednesday, November 9, 2005
DOD PERSONNEL CLEARANCES
Government Plan Addresses Some Long-standing Problems with DOD's Program,
But Concerns Remain
Statement of Derek B. Stewart, Director
Defense Capabilities and Management
GAO-06-233T
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
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separately.
www.gao.gov/cgi-bin/getrpt? GAO-06-233T .
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Derek B. Stewart at (202) 512-5559 or
stewartd@gao.gov.
Highlights of GAO-06-233T , a testimony before the Subcommittee on
Oversight of Government Management, the Federal Workforce, and the
District of Columbia, Committee on Homeland Security and Governmental
Affairs, U.S. Senate
November 9, 2005
DOD PERSONNEL CLEARANCES
Government Plan Addresses Some Long-standing Problems with DOD's Program,
But Concerns Remain
Unauthorized disclosure of classified information can cause up to
exceptionally grave damage to national security. The Department of Defense
(DOD) is responsible for about 2 million personnel with clearances that
allow them access to classified information. While most of these
clearances are for servicemembers and DOD's employees and contractors, DOD
is also responsible for contractors' clearances for more than 20 other
agencies, as well as for congressional staff. Due to long-standing
problems with DOD's clearance program, GAO designated it a high-risk area
in January 2005. In February 2005, when DOD transferred its personnel
security investigative functions to the Office of Personnel Management
(OPM), the average wait for a top secret clearance governmentwide was over
1 year. In June 2005, Executive Order 13381 gave the Office of Management
and Budget (OMB) authority to retain or assign to any executive agency any
process relating to determinations of eligibility for access to classified
information. OPM is assisting OMB with the development of the plan.
GAO was asked to assess the government plan. This testimony will provide
GAO's preliminary review of how well the government plan (1) adheres to
the standards of comprehensive strategic planning and (2) addresses the
timeliness and quality of the security clearance process. Finally, GAO
will discuss the actions required to remove DOD's program from GAO's
high-risk list.
We are encouraged by the level of commitment demonstrated by OMB in
overseeing the preparation of the government plan for addressing problems
in the personnel security clearance process. The plan represents an
important step toward addressing some long-standing concerns GAO has
raised in this area. It includes some elements that a comprehensive
strategic plan should contain, such as metrics that will be used to
monitor the timeliness of the security clearance process governmentwide.
However, the plan provides few details on other features that GAO looks
for in a comprehensive strategic plan. For example, in some cases, the
plan does not provide details on discrete actions the government would
take or their projected completion dates. In addition, the plan does not
always include details on the resources required to accomplish the plan's
objectives. Finally, the plan does not describe potential risks or
mitigation plans to address potential risks.
Although the government plan establishes metrics to address the timeliness
of the security clearance process, they focus on some phases of the
process more than others. Specifically, the plan identifies a wide variety
of metrics for monitoring the timeliness of security clearance
investigations, but it does little to address timeliness in the
adjudication phase of the process. The government plan also provides
quarterly goals for different types of investigations. However, the plan
does not identify baseline measures or interim goals for average
adjudication processing time.
Although it explicitly acknowledges that agencies have concerns about the
quality of investigations and adjudications, the government plan devotes
little attention to monitoring and improving the quality of the personnel
security clearance process. The plan's primary metric for measuring the
quality of investigations-the percentage of investigations returned by
requesting agencies due to incomplete case files-is not, by itself, a
valid indicator of the quality of investigative work. Other or additional
statistics, such as the number of counterintelligence leads generated from
security clearance investigations, may be needed. The government plan did
not identify a metric for assessing the quality of adjudications, although
GAO and other agencies have identified actions that would facilitate
monitoring and improvement of the quality of this portion of the personnel
security clearance process.
DOD must correct previously identified problems before its personnel
security clearance program can be removed from the high-risk list. Before
removing DOD's personnel security clearance program from the high-risk
list, GAO will examine whether OMB, OPM, and DOD have satisfied certain
criteria, including the establishment of leadership support, sufficient
resources to resolve the risk, and a corrective action plan. GAO's
criteria also include the presence of a program to monitor and
independently validate the effectiveness and sustainability of any
corrective actions and the agency's ability to demonstrate the
implementation of corrective measures.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.
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