Personnel Clearances: Key Factors to Consider in Efforts to	 
Reform Security Clearance Processes (27-FEB-08, GAO-08-352T).	 
                                                                 
In 2004, Congress passed the Intelligence Reform and Terrorism	 
Prevention Act to reform security clearance processes. Much of	 
GAO's experience in evaluating personnel security clearance	 
processes over the decades has consisted of examining the	 
Department of Defense's (DOD) program, which maintains about 2.5 
million clearances on servicemembers, DOD civilian employees,	 
legislative branch employees, and industry personnel working for 
DOD and 23 other federal agencies. Long-standing delays in	 
processing applications--and other problems in DOD's clearance	 
program--led GAO to designate it a high-risk area in 2005. GAO	 
also has documented clearance-related problems in other agencies.
For this hearing, GAO was asked to identify key factors that	 
could be applied in personnel security clearance reform efforts. 
To identify key factors, GAO drew upon its past reports and	 
institutional knowledge. For those reports, GAO reviewed laws,	 
executive orders, policies, reports, and other documentation	 
related to the security clearance process; examined samples of	 
cases of personnel granted top secret eligibility; compared	 
documentation in those sampled cases against federal standards;  
and interviewed a range of cognizant government officials.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-352T					        
    ACCNO:   A81109						        
  TITLE:     Personnel Clearances: Key Factors to Consider in Efforts 
to Reform Security Clearance Processes				 
     DATE:   02/27/2008 
  SUBJECT:   Eligibility determinations 			 
	     Interagency relations				 
	     Personnel qualifications				 
	     Personnel security clearance programs		 
	     Personnel security policies			 
	     Policy evaluation					 
	     Program evaluation 				 
	     Reporting requirements				 
	     Security clearance backlogs			 
	     Security clearances				 
	     Program goals or objectives			 
	     GAO High Risk Series				 

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GAO-08-352T

   

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Testimony: 

Before the Subcommittee on Intelligence Community Management, Permanent 
Select Committee on Intelligence, House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery Expected at 9:30 a.m. EST: 

Wednesday, February 27, 2008: 

Personnel Clearances: 

Key Factors to Consider in Efforts to Reform Security Clearance 
Processes: 

Statement of Brenda S. Farrell: 
Director, Defense Capabilities and Management: 

GAO-08-352T: 

GAO Highlights: 

Highlights of GAO-08-352T, a testimony before the Subcommittee on 
Intelligence Community Management, Permanent Select Committee on 
Intelligence, House of Representatives. 

Why GAO Did This Study: 

In 2004, Congress passed the Intelligence Reform and Terrorism 
Prevention Act to reform security clearance processes. Much of GAOï¿½s 
experience in evaluating personnel security clearance processes over 
the decades has consisted of examining the Department of Defenseï¿½s 
(DOD) program, which maintains about 2.5 million clearances on 
servicemembers, DOD civilian employees, legislative branch employees, 
and industry personnel working for DOD and 23 other federal agencies. 
Long-standing delays in processing applicationsï¿½and other problems in 
DODï¿½s clearance programï¿½led GAO to designate it a high-risk area in 
2005. GAO also has documented clearance-related problems in other 
agencies. 

For this hearing, GAO was asked to identify key factors that could be 
applied in personnel security clearance reform efforts. To identify key 
factors, GAO drew upon its past reports and institutional knowledge. 
For those reports, GAO reviewed laws, executive orders, policies, 
reports, and other documentation related to the security clearance 
process; examined samples of cases of personnel granted top secret 
eligibility; compared documentation in those sampled cases against 
federal standards; and interviewed a range of cognizant government 
officials. 

What GAO Found: 

Current and future efforts to reform personnel security clearance 
processes should consider, among other things, the following four key 
factors: determining whether clearances are required for positions, 
incorporating quality control steps throughout the clearance processes, 
establishing metrics for assessing all aspects of clearance processes, 
and providing Congress with the long-term funding requirements of 
security clearance reform. Requesting a clearance for a position in 
which it will not be needed, or in which a lower-level clearance would 
be sufficient, will increase both costs and investigative workload 
unnecessarily. For example, changing the clearance needed for a 
position from a secret to top secret increases the investigative 
workload for that position about 20-fold and uses 10 times as many 
investigative staff hours. 

Emphasis on quality in clearance processes could promote positive 
outcomes, including more reciprocity among agencies in accepting each 
othersï¿½ clearances. Building quality throughout clearance processes is 
important, but government agencies have paid little attention to 
quality, despite GAOï¿½s repeated suggestions to place more emphasis on 
quality. Even though GAO identified the governmentï¿½s primary metric for 
assessing qualityï¿½the percentage of investigative reports returned for 
insufficiency during the adjudicative phaseï¿½as inadequate by itself in 
1999, the Office of Management and Budget and the Office of Personnel 
Management continue to use that metric. Concerns about the quality of 
investigative and adjudicative work underlie the continued reluctance 
of agencies to accept clearances issued by other agencies; as a result, 
government resources are used to conduct duplicative investigations and 
adjudications. 

Many efforts to monitor clearance processes emphasize measuring 
timeliness, but additional metrics could provide a fuller picture of 
clearance processes. The emphasis on timeliness is due in part to 
recent legislation that provides specific guidelines regarding the 
speed with which clearances should be completed and requires annual 
reporting of that information to Congress. GAO has highlighted a 
variety of metrics in its reports (e.g., completeness of investigative 
and adjudicative reports, staffï¿½s and customersï¿½ perceptions of the 
processes, and the adequacy of internal controls), all of which could 
add value in monitoring clearance processes and provide better 
information to allow improved oversight by Congress and the Executive 
Branch. 

Another factor to consider in reform efforts is providing Congress with 
the long-term funding requirements to implement changes to security 
clearance processes. DODï¿½s August 2007 congressionally mandated report 
on industry clearances identified its immediate funding needs but did 
not include information on the funding requirements for fiscal year 
2009 and beyond. The inclusion of less than 2 future years of budgeting 
data in the DOD report limits Congressï¿½s ability to carry out its long-
term oversight and appropriations functions pertaining to industry 
personnel security clearances. 

To view the full product, click on [hyperlink, http://www.GAO-08-352T]. 
For more information, contact Brenda S. Farrell at (202) 512-3604 or 
[email protected]. 

[End of section] 

Madam Chairwoman and Members of the Subcommittee: 

Thank you for the opportunity to be here today for this hearing on 
security clearance reform which is intended to cover efforts being 
undertaken to improve the process, impediments to those reforms, 
planned future steps, and possible changes in the strategy for 
improving clearance processing timeliness. Congress passed and the 
President signed into law the Intelligence Reform and Terrorism 
Prevention Act of 2004 (IRTPA) to mandate a variety of steps be taken 
to reform security clearance processes. 

One recent step taken to reform security clearance processes was the 
formation of an interagency security clearance process reform team in 
June 2007. Agencies included in this governmentwide effort are the 
Office of the Director of National Intelligence, the Department of 
Defense (DOD), the Office of Management and Budget (OMB), and the 
Office of Personnel Management (OPM). The team's memorandum of 
agreement indicates that it seeks to develop, in phases, a reformed DOD 
and intelligence community security clearance process that allows the 
granting of high-assurance security clearances in the least time 
possible and at the lowest reasonable cost. The team's July 25, 2007, 
terms of reference indicate that it plans to deliver "a transformed, 
modernized, fair, and reciprocal security clearance process that is 
universally applicable" to DOD, the intelligence community, and other 
U.S. government agencies, no later than December 31, 2008. 

Since 1974, we have been examining personnel security clearance 
processes on behalf of the Congress. Through scores of reports and 
testimonies, we have acquired broad institutional knowledge that gives 
us a historical view of key factors that should be considered in 
clearance reform efforts. See a list of our related GAO products at the 
end of this statement. My comments will focus on four key factors that 
should be considered in clearance reform efforts. Before offering 
observations on these factors, I would like to provide some background 
information on our prior work and recent government reform efforts. 

Our reports have documented a wide variety of problems present in DOD's 
clearance program. Some of the problems that we noted in our 2007 high- 
risk report included incomplete and delayed investigative reports from 
OPM, which supplies about 90 percent of all federal clearance 
investigations, and DOD adjudicators granting clearance eligibility 
even though data were missing from the investigative reports used to 
make such determinations. While some of those findings are now about 2 
years old, DOD's August 2007 congressionally-mandated report on 
clearance investigations for industry personnel[Footnote 1] noted 
continuing problems. For example, during the first 6 months of fiscal 
year 2007, the end-to-end processing of initial top secret clearances 
took an average of 276 days; renewal top secret clearances averaged 335 
days; and both initial and renewal secret clearances averaged 208 days. 
On the other hand, DOD's report also noted progress that the department 
had made to improve its industry clearance program, including 
submitting 100 percent of the clearance requests electronically to 
improve timeliness and reduce the number of rejected applications and 
conducting research in an effort to improve the accuracy of its 
projections for future industry clearance needs. 

Much of our experience in evaluating personnel security clearance 
processes over the decades has emphasized examinations of DOD's program 
that maintains approximately 2.5 million clearances on servicemembers, 
DOD civilian employees, industry personnel for DOD and 23 other federal 
agencies, and employees in the federal legislative branch. Long- 
standing delays in determining clearance eligibility and other 
clearance challenges led us to designate DOD's personnel security 
clearance program as a high-risk area in January 2005 and continue that 
designation in the updated list of high-risk areas that we published in 
2007.[Footnote 2] The areas on our high-risk list received their 
designations because they are 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. 

You asked that we identify key factors that should be considered in 
personnel security clearance reform efforts. As requested, my statement 
today will address four factors for your consideration based on our 
prior work. They are (1) having a sound requirements-determination 
process in place, (2) building quality into every step of the clearance 
processes, (3) having a valid set of metrics for evaluating efficiency 
and effectiveness, and (4) providing Congress with the long-term 
funding requirements of security clearance reform. My statement draws 
on our prior work on clearance processes, which included reviews of 
clearance-related documents and interviews of senior officials at DOD 
and OPM, which has the primary responsibility for providing 
investigation services to DOD. Our work was performed in accordance 
with generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings and 
conclusions, based on our audit objectives. We believe that the 
evidence we obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Summary: 

Determining whether clearances are required for positions, establishing 
quality control steps throughout the clearance processes, developing 
metrics for assessing all aspects of clearance processes, and providing 
Congress with the long-term funding requirements of security clearance 
reform are important factors to consider in current and future efforts 
to reform personnel security clearance processes. Developing a sound 
requirements process is important because requests for clearances for 
positions that do not need a clearance or need a lower level of 
clearance increase investigative workload and costs unnecessarily. For 
example, changing the clearance needed for a position from secret to 
top secret increases the investigative workload for that one position 
about 20-fold. That is, top secret clearances must be performed twice 
as often as secret clearances (every 5 years versus 10 years) and 
require 10 times as many investigative staff hours (about 60 versus 6). 

Emphasis on quality in all processes could promote positive outcomes 
such as greater reciprocity of clearances. The steps to build quality 
throughout clearance processes are important, but government agencies 
have paid little attention to this factor despite our repeated 
suggestions to place more emphasis on it and its measurement. Even 
though in 1999 we identified the government's primary metric for 
assessing quality--the percentage of investigations returned because of 
problems--as being inadequate by itself, OMB and OPM have continued to 
use that metric as late as February 2008. Concerns about the quality of 
investigative and adjudicative work underlie the continued reluctance 
of agencies to accept the clearances issued by other agencies, thus 
using government resources to conduct duplicative investigations and 
adjudications. 

Efforts to monitor clearance processes emphasize timeliness 
measurement, but additional metrics could provide a fuller picture of 
clearance processes. The emphasis on timeliness is partially due to 
recent legislation which provides specific guidelines regarding the 
speed with which clearances should be completed and requires annual 
reporting of that information to Congress. Still, our past reports on 
clearance processes have highlighted a wide variety of metrics (e.g., 
completeness of investigative and adjudicative reports, staff and 
customers' perceptions of the processes, and adequacy of internal 
controls) which could add value in monitoring clearance processes and 
supply better information for greater congressional oversight. 

Providing Congress with the long-term funding requirements to implement 
changes to security clearance processes could enable more informed 
congressional oversight. DOD's August 2007 congressionally mandated 
report on industry personnel security clearances identified its 
immediate needs by submitting a projected need of $178.2 million for 
fiscal year 2007 and a projected need of approximately $300 million for 
fiscal year 2008. However, the report did not include information on 
the funding requirements for fiscal year 2009 and beyond. The inclusion 
of less than 2 future years of budgeting information in the DOD report 
limits Congress's ability to carry out its long-term oversight and 
appropriations functions pertaining to industry personnel security 
clearances. 

Background: 

Although our high-risk designation covers only DOD's program, our 
reports have also documented clearance-related problems affecting other 
agencies. For example, our October 2007 report on state and local 
information fusion centers cited two clearance-related challenges: (1) 
the length of time needed for state and local officials to receive 
clearances from the Federal Bureau of Investigation (FBI) and the 
Department of Homeland Security (DHS) and (2) the reluctance of some 
federal agencies--particularly DHS and FBI--to accept clearances issued 
by other agencies (i.e., clearance reciprocity).[Footnote 3] Similarly, 
our April 2007[Footnote 4] testimony on maritime security and selected 
aspects of the Security and Accountability for Every Port Act (SAFE 
Port Act[Footnote 5]) identified the challenge of obtaining clearances 
so that port security stakeholders could share information through area 
committees or interagency operational centers. The SAFE Port Act 
includes a specific provision requiring the Secretary of Homeland 
Security to sponsor and expedite individuals participating in 
interagency operational centers in gaining or maintaining their 
security clearances. 

Our reports have offered findings and recommendations regarding current 
impediments, and they offer key factors to consider in future reforms. 
For example, as the interagency security clearance process reform team 
develops a new governmentwide end-to-end clearance system, this reform 
effort provides an opportune time to consider factors for evaluating 
intermediate steps and the final system in order to optimize efficiency 
and effectiveness. The Director of National Intelligence's July 25, 
2007, memorandum provided the terms of reference for the security 
clearance process reform team and noted that a future Phase IV would be 
used to perform and evaluate demonstrations and to finalize the 
acquisition strategy. 

In designing a new personnel security clearance system, the Government 
Performance and Results Act of 1993 (GPRA) may be a useful resource for 
the team designing the system and the congressional committees 
overseeing the design and implementation. GPRA provides a framework for 
strategic performance planning and reporting intended to improve 
federal program effectiveness and hold agencies accountable for 
achieving results. Agencies that effectively implement GPRA's results- 
oriented framework clearly establish performance goals for which they 
will be held accountable, measure progress towards those goals, 
determine strategies and resources to effectively accomplish the goals, 
use performance information to make the programmatic decisions 
necessary to improve performance, and formally communicate results in 
performance reports. Our reports have also identified a number of 
directly relevant factors, such as those found in our November 2005 
testimony that evaluated an earlier governmentwide plan for improving 
the personnel security clearance process.[Footnote 6] 

Four Key Factors Should Be Considered in Efforts to Reform Security 
Clearance Processes: 

I will address the need for consideration of four key factors in my 
testimony: (1) a strong requirements-determination process, (2) quality 
emphasis in all clearance processes, (3) additional metrics to provide 
a fuller picture of clearance processes, and (4) long-term funding 
requirements of security clearance reform. 

A Strong Requirements-Determination Process Can Help Manage Clearance 
Workloads and Costs: 

The interagency security clearance process reform team established in 
July 2007 might want to address whether the numbers and levels of 
clearances are appropriate since this initial stage in the clearance 
process can affect workloads and costs in other clearance processes. 
For instance, the team may want to examine existing policies and 
practices to see if they need to be updated or otherwise modified. We 
are not suggesting that the numbers and levels of clearances are or are 
not appropriate--only that any unnecessary requirements in this initial 
phase use government resources that can be utilized for other purposes 
such as building additional quality into other clearance processes or 
decreasing delays in clearance processing. 

Figure 1 highlights the fact that the clearance process begins with 
establishing whether an incumbent's position requires a clearance, and 
if so, at what level. The numbers of requests for initial and renewal 
clearances and the levels of such clearance requests (phase 2 in fig. 
1) are two ways to look at outcomes of requirements setting in the 
clearance process. 

Figure 1: Six Phases in the Personnel Security Clearance Process: 

[See PDF for image] 

This figure illustrates the six phases in the personnel security 
clearance process, as follows: 

1. Requirements Setting:
The agency determines if a position requires the incumbent to access 
classified information, and if so, the level of clearance needed. 

2. Application Submission: 
Potential or actual incumbent provides application materials, and 
security officer reviews and submits request for investigation. 

3. Investigation: 
OPM, another agency, or one of their contractors conducts an 
investigation and forwards an investigative report to an adjudication 
facility. 

4. Adjudication: 
On the basis of information in the investigative report, adjudicators 
determine eligibility to access classified information. 

5. Appeal: 
If a clearance is denied or revoked, potential or actual incumbent can 
appeal the adjudicative decision. 

6. Clearance Updating: 
If incumbent has long-term need to access classified information, 
clearance is updated: top secret, 5 years; secret, 10 years; and 
confidential, 15 years. 

Source: GAO analysis of DOD-provided information. 

[End of figure] 

In our prior work, 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 the 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 part of their jobs. 
While having a large number of cleared personnel can give the military 
services, agencies, and industry a great deal of flexibility when 
assigning personnel, the investigative and adjudicative workloads that 
are required to provide the clearances and flexibility further tax a 
clearance process that already experiences delays in determining 
clearance eligibility. 

A change in the level of clearances being requested also increases the 
investigative and adjudicative workloads. For example, in our February 
2004 report on impediments to eliminating clearance backlogs,[Footnote 
7] we found that a growing percentage of all DOD requests for 
clearances for industry personnel was at the top secret level: 17 
percent of those requests were at the top secret level in 1995 but 27 
percent were at the top secret level in 2003. 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). In August 2006, OPM estimated that approximately 60 total staff 
hours are needed for each investigation for an initial top secret 
clearance and 6 total staff hours are needed for the investigation to 
support a secret or confidential clearance. The doubling of the 
frequency along with the increased effort to investigate and adjudicate 
each top secret reinvestigation adds costs and workload for the 
government. 

* Cost. For fiscal year 2008, OPM's standard billing rate is $3,711 for 
an investigation for an initial top secret clearance; $2,509 for an 
investigation to renew a top secret clearance, and $202 for an 
investigation for a secret clearance. The cost of getting and 
maintaining a top secret clearance for 10 years is approximately 30 
times greater than the cost of getting and maintaining a secret 
clearance for the same period. For example, an individual getting a top 
secret clearance for the first time and keeping the clearance for 10 
years would cost the government a total of $6,202 in current year 
dollars ($3,711 for the initial investigation and $2,509 for the 
reinvestigation after the first 5 years). In contrast, an individual 
receiving a secret clearance and maintaining it for 10 years would 
result in a total cost to the government of $202 ($202 for the initial 
clearance that is good for 10 years). 

* 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. Since (1) the average investigative report for a top secret 
clearance takes about 10 times as many investigative staff hours as the 
average investigative report for a secret clearance and (2) the top 
secret clearance must be renewed twice as often as the secret, the 
investigative workload increases about 20-fold. Additionally, the 
adjudicative workload increases about 4-fold. In 2007, DOD officials 
estimated that it took about twice as long to review an investigative 
report for a top secret clearance, which would need to be done twice as 
often as the secret clearance. 

Unless the new system developed by the interagency security clearance 
process reform team includes a sound requirements process, workload and 
costs may be higher than necessary. 

Emphasis on Quality in All Processes Could Promote Positive Outcomes 
Such as Greater Clearance Reciprocity: 

Since the late 1990s, GAO has emphasized a need to build more quality 
and quality monitoring into clearance processes to achieve positive 
goals such as promoting greater reciprocity and maximizing the 
likelihood that individuals who are security risks will be scrutinized 
more closely. In our November 2005 testimony on the earlier 
governmentwide plan to improve the clearance process, we noted that the 
plan devoted little attention to monitoring and improving the quality 
of the personnel security clearance process, and that limited attention 
and reporting about quality continue. When OMB issued its February 2007 
Report of the Security Clearance Oversight Group Consistent with Title 
III of the Intelligence Reform and Terrorism Prevention Act of 2004, it 
documented quality with a single metric. Specifically, it stated that 
OPM has developed additional internal quality control processes to 
ensure that the quality of completed investigations continue to meet 
the national investigative standards. OMB added that, overall, less 
than 1 percent of all completed investigations are returned to OPM from 
the adjudicating agencies for quality deficiencies. When OMB issued its 
February 2008 Report of the Security Clearance Oversight Group, it did 
not discuss the percentage of completed investigations that are 
returned to OPM or the development or existence of any other metric 
measuring the level of quality in security clearance processes or 
products. 

As part of our September 2006 report,[Footnote 8] we examined a 
different aspect of quality--the completeness of documentation in 
investigative and adjudicative reports. We found that OPM provided 
incomplete investigative reports to DOD adjudicators, which the 
adjudicators then used to determine top secret clearance eligibility. 
Almost all (47 of 50) of the sampled investigative reports we reviewed 
were incomplete based on requirements in the federal investigative 
standards. In addition, DOD adjudicators granted clearance eligibility 
without requesting additional information for any of the incomplete 
investigative reports and did not document that they considered some 
adjudicative guidelines when adverse information was present in some 
reports. 

GAO has long reported that it is problematic to equate the quality of 
investigations with the percentage of investigations that are returned 
by requesting agencies due to incomplete case files. For example, in 
October 1999 and again in our November 2005 evaluation of the 
governmentwide plan, we stated that the number of investigations 
returned for rework is not by itself a valid indicator of quality 
because adjudication officials said they were reluctant to return 
incomplete investigations in anticipation of further delays.[Footnote 
9] We additionally suggested that regardless of whether this metric 
continues to be used, the government might 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. Further, our September 
2006 report recommended that OMB's Deputy Director of Management 
require OPM and DOD to (1) submit their procedures for eliminating the 
deficiencies that we identified in their investigative and adjudicative 
documentation and (2) develop and report metrics on completeness and 
other measures of quality that will address the effectiveness of the 
new procedures. We believe that our recommendation still has merit, but 
the previously cited passage from the February 2007 OMB report does not 
describe the new procedures or provide statistics for the recommended 
new quality measures and the 2008 OMB report is silent on quality 
measures. 

As we noted in September 2006, the government cannot afford to achieve 
its timeliness goal by providing investigative and adjudicative reports 
that are incomplete in key areas required by federal investigative 
standards and adjudicative guidelines. Incomplete investigations and 
adjudications undermine the government's efforts to move toward greater 
clearance reciprocity. An interagency working group, the Security 
Clearance Oversight Steering Committee,[Footnote 10] noted that 
agencies are reluctant to be accountable for poor quality 
investigations and/or adjudications conducted by other agencies or 
organizations. To achieve fuller reciprocity, clearance-granting 
agencies need to have confidence in the quality of the clearance 
process. Without full documentation of investigative actions, 
information obtained, and adjudicative decisions, agencies could 
continue to require duplicative investigations and adjudications. 
Earlier, we stated that reciprocity concerns continue to exist, citing 
FBI and DHS reluctance to accept clearances issued by other agencies 
when providing information to personnel in fusion centers. 

Government Clearance Metrics Emphasize Timeliness Measurement, but 
Additional Metrics Could Provide a Fuller Picture of Clearance 
Processes: 

Much of the recent quantitative information provided on clearances has 
dealt with how much time it takes for the end-to-end processing of 
clearances (and related measures such as the numbers of various types 
of investigative and adjudicative reports generated); however, there is 
less quantitative information on other aspects of the clearance 
process. In our November 2005 testimony, we noted that the earlier 
government plan to improve the clearance process provided many metrics 
to monitor the timeliness of clearances governmentwide, but that plan 
detailed few of the other elements that a comprehensive strategic plan 
might contain. A similar emphasis on timeliness appears to be emerging 
for the future governmentwide clearance process. In the Director of 
National Intelligence's 500 Day Plan for Integration and Collaboration 
issued on October 10, 2007, the core initiative to modernize the 
security clearance process had only one type of metric listed under the 
heading about how success will be gauged. Specifically, the plan calls 
for measuring whether "performance of IC [Intelligence Community] 
agency personnel security programs meet or exceed IRTPA guidelines for 
clearance case processing times." 

While the February 2007 and 2008 OMB reports to Congress contain 
statistics and other information in addition to timeliness metrics 
(e.g., use of information technology and reciprocity-related 
procedures) and the joint team developing the new clearance process may 
be considering a wider range of metrics than timeliness only, an 
underlying factor in the emphasis on timeliness is IRTPA. [Footnote 11] 
Among other things, IRTPA established specific timeliness guidelines to 
be phased in over 5 years. The Act also states that, in the initial 
period which ends in 2009, each authorized adjudicative agency shall 
make a determination on at least 80 percent of all applications for 
personnel security clearance within an average of 120 days after the 
receipt of the application for a security clearance by an authorized 
investigative agency. The 120-day average period shall include a period 
of not longer than 90 days to complete the investigative phase of the 
clearance review and a period of not longer than 30 days to complete 
the adjudicative phase of the clearance review. Moreover, IRTPA also 
includes a requirement for a designated agency (currently OMB) to 
provide information on among other things the timeliness in annual 
reports through 2011, as OMB did in February 2008. 

Prior GAO reports as well as inspector general reports identify a wide 
variety of methods and metrics that program evaluators have used to 
examine clearance processes and programs. For example our 1999 
report[Footnote 12] on security clearance investigations used multiple 
methods to examine numerous issues that included: 

* documentation missing from investigative reports; 

* the training of investigators (courses, course content, and number of 
trainees); 

* investigators' perceptions about the process; 

* customer perceptions about the investigations; and: 

* internal controls to protect against fraud, waste, abuse, and 
mismanagement. 

Including these and other types of metrics in regular monitoring of 
clearance processes could add value in current and future reform 
efforts as well as supply better information for greater congressional 
oversight. 

Long-Term Funding Requirements Information Could Enable More Informed 
Congressional Oversight of Security Clearance Reform: 

The joint Security Clearance Process Reform team may also want to 
consider providing Congress with the long-term funding requirements to 
implement changes to security clearance processes enabling more 
informed congressional oversight. In a recent report to Congress, DOD 
provided funding requirements information that described its immediate 
needs for its industry personnel security program, but it did not 
include information about the program's long-term funding needs. 
Specifically, DOD's August 2007 congressionally mandated report on 
clearances for industry personnel provided less than 2 years of data on 
funding requirements. In its report, DOD identified its immediate needs 
by submitting an annualized projected cost of $178.2 million for fiscal 
year 2007 and a projected funding need of approximately $300 million 
for fiscal year 2008. However, the report did not include information 
on (1) the funding requirements for fiscal year 2009 and beyond even 
though the survey used to develop the funding requirements asked 
contractors about their clearance needs through 2010 and (2) the tens 
of millions of dollars that the Defense Security Service Director 
testified before Congress in May 2007 were necessary to maintain the 
infrastructure supporting the industry personnel security clearance 
program. 

As noted in our February 2008 report, the inclusion of less than 2 
future years of budgeting information in the DOD report limits 
Congress's ability to carry out its oversight and appropriations 
functions pertaining to industry personnel security 
clearances.[Footnote 13] Without more information on DOD's longer-term 
funding requirements for industry personnel security clearances, 
Congress lacks the visibility it needs to fully assess appropriations 
requirements. In addition, the long-term funding requirements to 
implement changes to security clearance processes are also needed to 
enable the executive branch to compare and prioritize alternative 
proposals for reforming the clearance processes. As the joint Security 
Clearance Process Reform team considers changes to the current 
clearance processes, it may also want to consider ensuring that 
Congress is provided with the long-term funding requirements necessary 
to implement any such reforms. 

Concluding Observations: 

We were encouraged when OMB undertook the development of an earlier 
governmentwide plan for improving the personnel security clearance 
process and have documented in our prior reports both DOD and 
governmentwide progress in addressing clearance-related problems. 
Similarly, the current joint effort to develop a new governmentwide end-
to-end security clearance system represents a positive step to address 
past impediments and manage security clearance reform efforts. Still, 
much remains to be done before a new system can be designed and 
implemented. GAO's experience in evaluating DOD's and governmentwide 
clearance plans and programs as well as its experience monitoring large-
scale, complex acquisition programs could help Congress in its 
oversight, insight, and foresight regarding security clearance reform 
efforts. 

Madam Chairwoman and Members of the Subcommittee, this concludes my 
prepared statement. I would be happy to answer any questions you may 
have at this time. 

Contact and Acknowledgments: 

For further information regarding this testimony, please contact me at 
(202) 512-3604 or [email protected]. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this statement. Individuals who made key contributions to this 
testimony are Jack E. Edwards, Acting Director; James P. Klein, Joanne 
Landesman, Charles Perdue, Karen D. Thornton, and Stephen K. Woods. 

[End of section] 

Related GAO Products: 

DOD Personnel Clearances: Improved Annual Reporting Would Enable More 
Informed Congressional Oversight. GAO-08-350. Washington, D.C.: 
February 13, 2008. 

Homeland Security: Federal Efforts Are Helping to Alleviate Some 
Challenges Encountered by State and Local Information Fusion Centers. 
GAO-08-35. Washington, D.C.: October 30, 2007. 

Defense Business Transformation: A Full-time Chief Management Officer 
with a Term Appointment Is Needed at DOD to Maintain Continuity of 
Effort and Achieve Sustainable Success. GAO-08-132T. Washington, D.C.: 
October 16, 2007. 

DOD Personnel Clearances: Delays and Inadequate Documentation Found For 
Industry Personnel. GAO-07-842T. Washington, D.C.: May 17, 2007. 

Maritime Security: Observations on Selected Aspects of the SAFE Port 
Act. GAO-07-754T. Washington, D.C.: April 26, 2007. 

High-Risk Series: An Update, GAO-07-310 (Washington, D.C.: January 
2007). 

DOD Personnel Clearances: Additional OMB Actions Are Needed To Improve 
The Security Clearance Process, GAO-06-1070. Washington, D.C.: 
September 2006. 

Managing Sensitive Information: DOD Can More Effectively Reduce the 
Risk of Classification Errors, GAO-06-706. Washington, D.C.: June 30, 
2006. 

DOD Personnel Clearances: Questions and Answers for the Record 
Following the Second in a Series of Hearings on Fixing the Security 
Clearance Process. GAO-06-693R. Washington, D.C.: June 14, 2006. 

DOD Personnel Clearances: New Concerns Slow Processing of Clearances 
for Industry Personnel. GAO-06-748T. Washington, D.C.: May 17, 2006. 

DOD Personnel Clearances: Funding Challenges and Other Impediments Slow 
Clearances for Industry Personnel. GAO-06-747T. Washington, D.C.: May 
17, 2006. 

Questions for the Record Related to DOD's Personnel Security Clearance 
Program and the Government Plan for Improving the Clearance Process. 
GAO-06-323R. Washington, D.C.: January 17, 2006. 

DOD Personnel Clearances: Government Plan Addresses Some Long-standing 
Problems with DOD's Program, But Concerns Remain. GAO-06-233T. 
Washington, D.C.: November 9, 2005. 

Defense Management: Better Review Needed of Program Protection Issues 
Associated with Manufacturing Presidential Helicopters. GAO-06-71SU. 
Washington, D.C.: November 4, 2005. 

Questions for the Record Related to DOD's Personnel Security Clearance 
Program. GAO-05-988R. Washington, D.C.: August 19, 2005. 

Industrial Security: DOD Cannot Ensure Its Oversight of Contractors 
under Foreign Influence Is Sufficient. GAO-05-681. Washington, D.C.: 
July 15, 2005. 

DOD Personnel Clearances: Some Progress Has Been Made but Hurdles 
Remain to Overcome the Challenges That Led to GAO's High-Risk 
Designation. GAO-05-842T. Washington, D.C.: June 28, 2005. 

DOD's High-Risk Areas: Successful Business Transformation Requires 
Sound Strategic Planning and Sustained Leadership. GAO-05-520T. 
Washington, D.C.: April 13, 2005. 

High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January 
2005. 

Intelligence Reform: Human Capital Considerations Critical to 9/11 
Commission's Proposed Reforms. GAO-04-1084T. Washington, D.C.: 
September 14, 2004. 

DOD Personnel Clearances: Additional Steps Can Be Taken to Reduce 
Backlogs and Delays in Determining Security Clearance Eligibility for 
Industry Personnel. GAO-04-632. Washington, D.C.: May 26, 2004. 

DOD Personnel Clearances: Preliminary Observations Related to Backlogs 
and Delays in Determining Security Clearance Eligibility for Industry 
Personnel. GAO-04-202T. Washington, D.C.: May 6, 2004. 

Industrial Security: DOD Cannot Provide Adequate Assurances That Its 
Oversight Ensures the Protection of Classified Information. GAO-04-332. 
Washington, D.C.: March 3, 2004. 

DOD Personnel Clearances: DOD Needs to Overcome Impediments to 
Eliminating Backlog and Determining Its Size. GAO-04-344. Washington, 
D.C.: February 9, 2004. 

[End of section] 

Footnotes: 

[1] DOD, Annual Report to Congress on Personnel Security Investigations 
for Industry and the National Industrial Security Program (August 
2007). This first of a series of annual reports was mandated by The 
John Warner National Defense Authorization Act for Fiscal Year 2007, 
Pub. L. No. 109-364, ï¿½347 (2006). 

[2] GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.: 
January 2005); and GAO, High-Risk Series: An Update, GAO-07-310 
(Washington, D.C.: January 2007). 

[3] GAO, Homeland Security: Federal Efforts Are Helping to Alleviate 
Some Challenges Encountered by State and Local Information Fusion 
Centers, GAO-08-35 (Washington, D.C.: Oct. 30, 2007). This report 
indicated that according to the 9/11 Commission, a breakdown in 
information sharing was a major factor contributing to the failure to 
prevent the attacks of September 11, 2001. Since then most states and 
some local governments have, largely on their own initiative, 
established fusion centers to address gaps in homeland security, 
terrorism, and law enforcement information sharing by the federal 
government and to provide a conduit of this information within the 
state. 

[4] GAO, Maritime Security: Observations on Selected Aspects of the 
SAFE Port Act, GAO-07-754T (Washington, D.C.: Apr. 26, 2007). 

[5] Pub. L. No. 109-347, 120 Stat. 1184 (2006). 

[6] GAO, DOD Personnel Clearances: Government Plan Addresses Some Long- 
standing Problems with DOD's Program, But Concerns Remain, GAO-06-233T 
(Washington, D.C.: Nov. 9, 2005). 

[7] 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). 

[8] GAO, DOD Personnel Clearances: Additional OMB Actions Are Needed to 
Improve the Security Clearance Process, GAO-06-1070 (Washington, D.C.: 
Sept. 28, 2006). 

[9] GAO-06-233T; and GAO, DOD Personnel: Inadequate Personnel Security 
Investigations Pose National Security Risks, GAO/NSIAD-00-12 
(Washington, D.C.: Oct. 27, 1999). 

[10] At that time, the committee was led by OMB's Deputy Director for 
Management and was composed of representatives from DOD, Homeland 
Security, Energy, Justice, Transportation, Commerce, State, the 
Director of National Intelligence, the National Security Council, and 
the National Archives and Records Administration. 

[11] Intelligence Reform and Terrorism Prevention Act of 2004, Pub. L. 
No. 108-458, ï¿½3001 (g) Reduction of Length of Personnel Security 
Clearance Process (2004). 

[12] GAO, DOD Personnel: Inadequate Personnel Security Investigations 
Pose National Security Risks, GAO/NSIAD-00-12 (Washington, D.C.: Oct. 
27, 1999). 

[13] GAO, DOD Personnel Clearances: Improved Annual Reporting Would 
Enable More Informed Congressional Oversight, GAO-08-350 (Washington, 
D.C.: Feb. 13, 2008). 

[End of section] 

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