Personnel Clearances: Key Factors for Reforming the Security	 
Clearance Process (22-MAY-08, GAO-08-776T).			 
                                                                 
Since 1974, GAO has examined personnel security clearance	 
processes and acquired a historical view of key factors to	 
consider in reform efforts. GAO placed the Department of	 
Defense's (DOD) personnel security clearance program, which	 
represents 80 percent of federal government clearances, on its	 
high-risk list in 2005 due to long-standing problems. These	 
problems include incomplete investigative reports from the Office
of Personnel Management (OPM), the agency primarily responsible  
for providing clearance investigation services; the granting of  
some clearances by DOD adjudicators even when required data were 
missing from the investigative reports used to make such	 
determinations; and delays in completing clearance processing.	 
Delays can lead to a heightened risk of disclosure of classified 
information, additional costs and delays in completing related	 
contracts, and problems retaining qualified personnel. DOD has	 
reported on these continuing delays. However, there has been	 
recent high-level governmentwide attention to improving the	 
process, including establishing a team to develop a reformed	 
federal government security clearance process. This statement	 
addresses four key factors that should be considered in personnel
security clearance reforms. This statement draws on GAO's past	 
work, which included reviews of clearance-related documents and  
interviews of senior officials at DOD and OPM.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-776T					        
    ACCNO:   A82168						        
  TITLE:     Personnel Clearances: Key Factors for Reforming the      
Security Clearance Process					 
     DATE:   05/22/2008 
  SUBJECT:   Background investigations				 
	     Classified defense information			 
	     Classified information				 
	     Cost analysis					 
	     Cost overruns					 
	     Data integrity					 
	     Eligibility determinations 			 
	     Employee retention 				 
	     Employees						 
	     Funds management					 
	     Information leaking				 
	     Investigations by federal agencies 		 
	     Personnel security clearance programs		 
	     Personnel security policies			 
	     Quality improvement				 
	     Reporting requirements				 
	     Requirements definition				 
	     Risk factors					 
	     Risk management					 
	     Schedule slippages 				 
	     Security clearance backlogs			 
	     Security clearances				 
	     Security investigations				 
	     Strategic planning 				 
	     Cost estimates					 
	     Program goals or objectives			 
	     Program implementation				 
	     GAO High Risk Series				 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Product.                                                 **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
GAO-08-776T


This is the accessible text file for GAO report number GAO-08-776T 
entitled 'Personnel Clearances: Key Factors for Reforming the Security 
Clearance Process' which was released on May 23, 2008.

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to [email protected]. 

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. 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. 

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: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 2:30 p.m. EDT:
Thursday, May 22, 2008: 

Personnel Clearances: 

Key Factors for Reforming the Security Clearance Process: 

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

GAO-08-776T: 

GAO Highlights: 

Highlights of GAO-08-776T, 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. 

Why GAO Did This Study: 

Since 1974, GAO has examined personnel security clearance processes and 
acquired a historical view of key factors to consider in reform 
efforts. GAO placed the Department of Defenseï¿½s (DOD) personnel 
security clearance program, which represents 80 percent of federal 
government clearances, on its high-risk list in 2005 due to long-
standing problems. These problems include incomplete investigative 
reports from the Office of Personnel Management (OPM), the agency 
primarily responsible for providing clearance investigation services; 
the granting of some clearances by DOD adjudicators even when required 
data were missing from the investigative reports used to make such 
determinations; and delays in completing clearance processing. Delays 
can lead to a heightened risk of disclosure of classified information, 
additional costs and delays in completing related contracts, and 
problems retaining qualified personnel. DOD has reported on these 
continuing delays. However, there has been recent high-level 
governmentwide attention to improving the process, including 
establishing a team to develop a reformed federal government security 
clearance process. 

This statement addresses four key factors that should be considered in 
personnel security clearance reforms. This statement draws on GAOï¿½s 
past work, which included reviews of clearance-related documents and 
interviews of senior officials at DOD and OPM. 

What GAO Found: 

Efforts to reform personnel security clearance processes should 
consider, among other things, the following four key factors: (1) a 
strong requirements-determination process, (2) quality in all clearance 
processes, (3) metrics to provide a fuller picture of clearance 
processes, and (4) long-term funding requirements of security clearance 
reform. In February 2008, GAO noted that a sound requirements process 
is important because 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, the cost of obtaining and maintaining a top 
secret clearance for 10 years is approximately 30 times greater than 
the cost of obtaining and maintaining a secret clearance for the same 
period. Also, changing a positionï¿½s clearance level from secret to top 
secret increases the investigative workload for that position about 20-
fold. 

Building quality throughout the clearance process could promote 
positive outcomes, including more reciprocity governmentwide. However, 
agencies have paid little attention to this factor despite GAOï¿½s 2006 
recommendation to place more emphasis on quality. For example, the 
Office of Management and Budgetï¿½s (OMB) February 2007 report on 
security clearances documented quality with a single metric in only one 
of the six phases of the process. Further, OMB did not discuss the 
development or existence of any metric measuring the level of quality 
in security clearance processes or products in its February 2008 
report. Concerns about the quality of investigative and adjudicative 
work underlie the continued reluctance of agencies to accept clearances 
issued by other agencies; thus, government resources may be used to 
conduct duplicative investigations and adjudications. 

Federal agenciesï¿½ efforts to monitor clearance processes emphasize 
timeliness, but additional metrics should be developed to provide a 
fuller picture of the performance of the clearance process. GAO has 
highlighted a variety of metrics in its reports (e.g., completeness of 
investigative reports, staffï¿½s and customersï¿½ perceptions of the 
process, and the adequacy of internal controls), all of which could add 
value in monitoring clearance processes. The emphasis on timeliness is 
due in part to the Intelligence Reform and Terrorism Prevention Act of 
2004 which provides guidelines for the speed of completing clearances 
and requires annual reporting of that information to Congress. 

Providing Congress with the long-term funding requirements to implement 
changes to security clearance processes could enable more-informed 
congressional oversight. Reform efforts should identify long-term 
funding requirements to implement proposed changes, so that decision 
makers can compare and prioritize alternate reform proposals in times 
of fiscal constraints. The absence of long-term funding requirements to 
implement reforms would limit decision makersï¿½ï¿½in the executive and 
legislative branchesï¿½ability to carry out their budgetary development 
and oversight functions. 

To view the full product, click on [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-776T]. For more information, 
contact Brenda S. Farrell at (202) 512-3604 or [email protected]. 

[End of section] 

Chairman Akaka and Members of the Subcommittee: 

Thank you for the opportunity to be here today to discuss reforming the 
federal government's personnel security clearance process. Since 1974, 
we have been examining personnel security clearance processes to assist 
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. A list 
of our related GAO products is provided at the end of this statement. 
Specifically, we have testified on clearance-related issues in four 
prior hearings that this Subcommittee has held since January 2005, when 
we first placed the Department of Defense's (DOD) personnel security 
clearance program--which represents about 80 percent of the security 
clearances adjudicated by the federal government--on our list of high- 
risk government programs and operations.[Footnote 1] 

We placed DOD's personnel security clearance program on our high-risk 
list in 2005 and again in 2007[Footnote 2] because of a variety of long-
standing problems in the program. Some of those problems included (1) 
incomplete investigative reports from the Office of Personnel 
Management (OPM), the agency that supplies about 90 percent of all 
federal clearance investigations, including those for DOD; (2) the 
granting of some clearances by DOD adjudicators even though required 
data were missing from the investigative reports used to make such 
determinations; and (3) long-standing delays in completing clearances. 
We have recently initiated additional work to examine the timeliness 
and quality of personnel security clearances in DOD. This work will 
help determine whether DOD's personnel security clearance program 
should remain on our 2009 high-risk list. 

In February 2008, we testified[Footnote 3] that DOD's August 2007 
report to Congress[Footnote 4] noted continuing problems with delayed 
processing of industry personnel security clearances. We testified that 
the time required to process clearances continues to exceed time 
requirements established by the Intelligence Reform and Terrorism 
Prevention Act of 2004. This law currently requires adjudicative 
agencies to make a determination on at least 80 percent of all 
applications for a security clearance within an average of 120 days 
after the date of receipt of the application, with no longer than 90 
days allotted for the investigation and 30 days allotted for the 
adjudication. DOD's August 2007 congressionally-mandated report on 
clearances for industry personnel described continuing delays in the 
processing of clearances. 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 of top secret 
clearances, 335 days; and all secret clearances, 208 days. Moreover, 
DOD's February 2008 congressionally-mandated report[Footnote 5] on 
clearance investigations for industry personnel noted that problems 
persist. Specifically, during the second half of fiscal year 2007, DOD 
reported that the end-to-end processing of initial top secret 
clearances averaged 311 days, renewal of top secret clearances averaged 
444 days, and both initial and renewal of secret and confidential 
clearances averaged 229 days. 

Problems in the clearance program can negatively affect national 
security. For example, delays reviewing security clearances for 
personnel who are already doing classified work can lead to a 
heightened risk of disclosure of classified information. In contrast, 
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. 

While delays continue in completing the end-to-end processing of 
security clearances, recent high-level governmentwide attention has 
been focused on improving the clearance process. For example, we 
previously reported that the Office of Management and Budget's (OMB) 
Deputy Director for Management has led efforts to improve 
governmentwide security clearance processes since June 2005. In 
addition, in June 2007, the OMB Deputy Director--in collaboration with 
the Director of National Intelligence and the Under Secretary of 
Defense for Intelligence--established the Joint Security and 
Suitability Reform Team (hereafter referred to as the Joint Reform 
Team). The Joint Reform Team was established to develop a reformed 
federal government security clearance process.[Footnote 6] On February 
5, 2008, the President issued a memorandum that called for aggressive 
reform efforts of the security clearance process, acknowledged the work 
being performed by the Joint Reform Team, and directed that the team 
submit to the President an initial reform plan no later than April 30, 
2008. As directed, the Joint Reform Team submitted a plan to the 
President on April 30, 2008, which presents the proposed design of a 
transformed hiring and clearing process. 

The reformed security clearance process developed by the Joint Reform 
Team would be applicable not only to DOD but across the federal 
government including the intelligence community. In February, we 
testified before this subcommittee about areas in which we could 
support the intelligence committees and community on oversight of 
management reforms, including the security clearance process. Recently, 
we received two requests from the U.S. House of Representatives 
Permanent Select Committee on Intelligence to review security clearance 
programs in the intelligence community. Specifically, we have been 
asked to assess (1) the Joint Reform Team's reform efforts and (2) the 
timeliness and quality of personnel security clearances in the 
intelligence community. 

For this testimony, you asked that we identify key factors that should 
be considered in personnel security clearance reform efforts. My 
statement today draws on our prior work on clearance processes since 
2004, which included reviews of clearance-related documents and 
interviews of senior officials at DOD and OPM, which has the primary 
responsibility for providing clearance 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: 

Ensuring a strong requirements-determination process, building quality 
in all clearance processes, including metrics to provide a fuller 
picture of clearance processes, and providing long-term funding 
requirements of security clearance reform are important factors to 
consider in efforts to reform the personnel security clearance process. 
First, ensuring a strong requirements-determination process can help 
the government manage the workloads and costs associated with the 
security clearance process. 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. Second, building quality in all 
security clearance processes could promote positive outcomes such as 
greater reciprocity of clearances. 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 may be used to conduct duplicative investigations 
and adjudications. Third, efforts to monitor clearance processes 
emphasize timeliness measurement, but additional metrics should be 
developed to provide a fuller picture of the performance of the 
clearance process. We have highlighted a variety of metrics in our 
reports (e.g., completeness of investigative reports, staff's and 
customers' perceptions of the process, and the adequacy of internal 
controls), all of which could add value in monitoring different aspects 
of the quality of clearance processes. Fourth, providing Congress with 
the long-term funding requirements in reports on implementing changes 
to security clearance processes could enable more-informed 
congressional oversight. As noted in our February 2008 report on 
industry personnel security clearances, limiting or excluding funding 
information in reports on changes to security clearance processes 
reduces the utility of information for Congress and the executive 
branch by limiting decision makers' ability to compare and prioritize 
alternate reform proposals when carrying out their budgetary 
development and oversight functions. 

Background: 

Military servicemembers, federal workers, and industry personnel must 
generally obtain security clearances to gain access to classified 
information. The three clearance level categories are: top secret, 
secret, and confidential. The level of classification denotes the 
degree of protection required for information and the amount of damage 
that unauthorized disclosure could reasonably cause to national 
security. 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.[Footnote 7] 

DOD's Office of the Under Secretary of Defense for Intelligence has 
responsibility for determining eligibility for clearances for 
servicemembers, DOD civilian employees, and industry personnel 
performing work for DOD and 23 other federal agencies, as well as 
employees in the federal legislative branch.[Footnote 8] That 
responsibility includes obtaining background investigations, primarily 
through OPM. Within DOD, government employees use the information in 
OPM-provided investigative reports to determine clearance eligibility 
of clearance subjects. DOD's program maintains approximately 2.5 
million clearances. 

Although our high-risk designation covers only DOD's program, our 
reports have documented clearance-related problems affecting other 
agencies such as the Department of Homeland Security (DHS). For 
example, our October 2007 report on state and local information fusion 
centers[Footnote 9] 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 DHS, and 
(2) the reluctance of some federal agencies--particularly DHS and FBI-
-to accept clearances issued by other agencies (i.e., clearance 
reciprocity). Similarly, our April 2007 testimony[Footnote 10] on 
maritime security and selected aspects of the Security and 
Accountability for Every Port Act of 2006[Footnote 11] (SAFE Port Act) 
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. 

Recent events affecting clearance programs across the federal 
government include the passage of the Intelligence Reform and Terrorism 
Prevention Act (IRTPA) of 2004 and the issuance of the June 2005 
Executive Order 13381, "Strengthening Processes Relating to Determining 
Eligibility for Access to Classified National Security Information." 
IRTPA included milestones for reducing the time to complete clearances, 
general specifications for a database on security clearances, and 
requirements for reciprocity of clearances. The executive order stated, 
among other things, that OMB was to ensure the effective implementation 
of policy regarding appropriately uniform, centralized, efficient, 
effective, timely, and reciprocal agency functions relating to 
determining eligibility for access to classified national security 
information. Since 2005, OMB's Deputy Director for Management has taken 
several actions to improve the security clearance process, including 
establishing an interagency working group to improve the reciprocal 
acceptance of clearances issued by other agencies and taking a lead 
role in preparing a November 2005 strategic plan to improve personnel 
security clearance processes governmentwide. 

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

In our prior work, we identified four key factors that should be 
considered to reform the security clearance process. These include (1) 
ensuring a strong requirements-determination process, (2) building 
quality in all clearance processes, (3) developing additional metrics 
to provide a fuller picture of clearance processes, and (4) including 
long-term funding requirements of security clearance reform. 

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

As we testified in February 2008, ensuring a strong requirements- 
determination process can help the government manage the workloads and 
costs associated with the security clearance process. Requirements- 
determination in the clearance process begins with establishing whether 
a position requires a clearance, and if so, at what level. We have 
previously stated that any reform process should 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 stages. While having a large number of cleared personnel can 
give the military services, agencies, and industry a great deal of 
flexibility when assigning personnel, having unnecessary requirements 
for security clearances increases the investigative and adjudicative 
workloads that are required to provide the clearances and flexibility, 
and further taxes 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, an increase in the proportion of 
investigations at the top secret level increases workloads and costs 
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 each 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 obtaining and 
maintaining a top secret clearance for 10 years is approximately 30 
times greater than the cost of obtaining 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 $6,220 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. However, the 
investigation for a top secret clearance 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. The 
investigative workload for a top secret clearance increases about 20- 
fold compared to the workload for a secret clearance, 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. 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 for a 
secret clearance. 

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. Unless reforms 
ensure a strong requirements-determination process is present, workload 
and costs may be higher than necessary. 

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

We have emphasized--since the late 1990s--a need to build more quality 
and quality monitoring throughout the clearance process to promote 
positive outcomes such as greater clearance reciprocity. In our 
November 2005 testimony on the previous governmentwide strategic 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 continues. In addition, when OMB issued its February 2007 
annual report on security clearances,[Footnote 12] it documented 
quality with a single metric in one of the six phases of the security 
clearance process (i.e., requirements setting, application submission, 
investigation, adjudication, appeal, and clearance updating). OMB 
stated 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 annual report 
on security clearances,[Footnote 13] 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. 

We have also 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 strategic 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 as they anticipated this would lead to 
further delays. As part of our September 2006 report,[Footnote 14] we 
examined a different aspect of quality--the completeness of 
documentation in investigative and adjudicative reports. We found that 
OPM provided some incomplete investigative reports to DOD adjudicators, 
which the adjudicators then used to determine top secret clearance 
eligibility. 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. In our September 2006 report, we recommended 
that regardless of whether the metric on investigations returned for 
rework continues to be used, OMB's Deputy Director for Management 
should require OPM and DOD to develop and report metrics on 
investigative and adjudicative completeness and other measures of 
quality. In his comments to our report, OMB's Deputy Director for 
Management did not take exception to this recommendation. We are 
currently reviewing the timeliness and quality of DOD personnel 
security clearances in ongoing work and plan to review any actions 
taken by OMB with regard to this recommendation. 

In September 2006, we also reported that while eliminating delays in 
clearance processes is an important goal, the government cannot afford 
to achieve that goal at the expense of quality. We additionally 
reported that the lack of full reciprocity of clearances is an 
outgrowth of agencies' concerns that other agencies may have granted 
clearances based on inadequate investigations and adjudications. An 
interagency working group, the Security Clearance Oversight Steering 
Committee,[Footnote 15] noted that agencies are reluctant to be 
accountable for poor quality investigations 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. 

It will be important for any reform process to incorporate both quality 
and quality monitoring and reporting throughout the clearance process. 
In their absence, reciprocity concerns will continue to exist and 
Congress will not have sufficient information to perform its oversight 
function. 

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

As we testified in February 2008, reform efforts should also consider 
metrics beyond timeliness to evaluate the clearance processes and 
procedures and to provide a more complete picture of the performance of 
a reformed clearance process.[Footnote 16] 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 17] on 
security clearance investigations used multiple methods to examine 
numerous issues that included: 

* documentation missing from investigative reports; 

* investigator training (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. 

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 
such as the metrics listed above. In February 2008, we noted that 
including these additional metrics could add value in monitoring 
clearance processes and provide a more complete picture of the 
performance of a reformed clearance process. In our November 2005 
testimony, we noted that a previous government plan to improve the 
clearance process placed an emphasis on monitoring the timeliness of 
clearances governmentwide, but that plan detailed few of the other 
elements that a comprehensive strategic plan might contain. 

An underlying factor that places emphasis on timeliness is the 
Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA). 
[Footnote 18] Among other things, IRTPA established specific timeliness 
guidelines to be phased in over 5 years. The act states that, in the 
initial period that ends in 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 after 
the receipt of the application for a security clearance by an 
authorized investigative agency. This 120-day period includes no more 
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. By December 17, 2009, the 
act will require that adjudicative agencies make a determination on at 
least 90 percent of all applications for a security clearance within an 
average of 60 days after the date of receipt of the application, 
including no more than 40 days for the investigation and 20 days for 
the adjudication. Moreover, IRTPA also includes a requirement for a 
designated agency (currently OMB) to provide information on, among 
other things, the timeliness of security clearance determinations in 
annual reports to Congress through 2011, as OMB did most recently in 
February 2008. While timeliness is important, other metrics are also 
needed to evaluate a reformed clearance process. 

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

In February 2008, we recommended that the Joint Reform Team also 
provide Congress with long-term funding requirements as it develops 
plans to reform the security clearance process. We have previously 
reported that DOD has not provided Congress with long-term funding 
needs for industry personnel security clearances.[Footnote 19] In 
February 2008, we reported that in its August 2007 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 required 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,[Footnote 20] limiting or 
excluding funding information in security clearance reports for 
Congress and the executive branch reduces the utility of those reports 
in developing and overseeing budgets for reform. 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 
especially as the nation's fiscal imbalances constrain federal funding. 
Without information on long-term funding requirements, both Congress 
and the executive branch will not have sufficient information to 
perform their budget oversight and development functions. 

Conclusions: 

We are encouraged that the Joint Reform Team issued an initial plan to 
develop a reformed federal government security clearance process. As 
the Joint Reform Team develops its reform initiatives, we encourage the 
team to consider the four factors highlighted in my statement today. As 
much remains to be done before a new system can be designed and 
implemented, we look forward to evaluating the Joint Reform Team's 
efforts to assist Congress in its oversight. 

Chairman Akaka 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 David E. Moser, Assistant Director; Renee S. Brown; 
Shvetal Khanna; James P. Klein; Caryn Kuebler; Ron La Due Lake; Gregory 
Marchand; and Brian D. Pegram. 

[End of section] 

Related GAO Products: 

Personnel Clearances: Key Factors to Consider in Efforts to Reform 
Security Clearance Processes. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-352T]. Washington, D.C.: February 27, 2008. 

DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts 
to Improve Clearance Processes for Industry Personnel. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-470T]. Washington, D.C.: 
February 13, 2008. 

DOD Personnel Clearances: Improved Annual Reporting Would Enable More 
Informed Congressional Oversight. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?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. 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?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. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-132T]. Washington, D.C.: 
October 16, 2007. 

DOD Personnel Clearances: Delays and Inadequate Documentation Found for 
Industry Personnel. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-
07-842T]. Washington, D.C.: May 17, 2007. 

Maritime Security: Observations on Selected Aspects of the SAFE Port 
Act. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?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. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-1070]. Washington, D.C.: September 28, 2006. 

Managing Sensitive Information: DOD Can More Effectively Reduce the 
Risk of Classification Errors. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?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. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-
693R]. Washington, D.C.: June 14, 2006. 

DOD Personnel Clearances: New Concerns Slow Processing of Clearances 
for Industry Personnel. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-748T]. Washington, D.C.: May 17, 2006. 

DOD Personnel Clearances: Funding Challenges and Other Impediments Slow 
Clearances for Industry Personnel. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-747T]. Washington, D.C.: May 17, 2006. 

Questions for the Record Related to DOD's Personnel Security Clearance 
Program and the Government Plan for Improving the Clearance Process. 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-323R]. Washington, 
D.C.: January 17, 2006. 

DOD Personnel Clearances: Government Plan Addresses Some Long-standing 
Problems with DOD's Program, But Concerns Remain. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-06-233T]. Washington, D.C.: 
November 9, 2005. 

Defense Management: Better Review Needed of Program Protection Issues 
Associated with Manufacturing Presidential Helicopters. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-06-71SU]. Washington, D.C.: 
November 4, 2005. 

Questions for the Record Related to DOD's Personnel Security Clearance 
Program. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-988R]. 
Washington, D.C.: August 19, 2005. 

Industrial Security: DOD Cannot Ensure Its Oversight of Contractors 
under Foreign Influence Is Sufficient. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?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. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-
842T]. Washington, D.C.: June 28, 2005. 

DOD's High-Risk Areas: Successful Business Transformation Requires 
Sound Strategic Planning and Sustained Leadership. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-05-520T]. Washington, D.C.: April 
13, 2005. 

High-Risk Series: An Update. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-05-207]. Washington, D.C.: January 2005. 

Intelligence Reform: Human Capital Considerations Critical to 9/11 
Commission's Proposed Reforms. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?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. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?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. [hyperlink, http://www.gao.gov/cgi-bin/getrpt?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. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-04-332]. Washington, D.C.: March 
3, 2004. 

DOD Personnel Clearances: DOD Needs to Overcome Impediments to 
Eliminating Backlog and Determining Its Size. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-04-344]. Washington, D.C.: 
February 9, 2004. 

[End of section] 

Footnotes: 

[1] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-05-207] (Washington, D.C.: 
January 2005). 

[2] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-07-310] (Washington, D.C.: 
January 2007). 

[3] GAO, DOD Personnel Clearances: DOD Faces Multiple Challenges in Its 
Efforts to Improve Clearance Processes for Industry Personnel, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-470T] (Washington, 
D.C.: Feb. 13, 2008). 

[4] 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). 

[5] DOD, Annual Report to Congress on Personnel Security Investigations 
for Industry and the National Industrial Security Program (February 
2008). 

[6] Since June 2007, the goal of the Joint Reform Team expanded to 
include the elimination of duplicative steps in the investigations for 
security clearances and suitability determinations for federal 
employment. In addition, OPM is also now a member of the Joint Reform 
Team. 

[7] 5 C.F.R. ï¿½ 1312.4 (2008). 

[8] DOD, National Industrial Security Program: Operating Manual, DOD 
5220.22-M (Feb. 28, 2006), notes that heads of agencies are required to 
enter into agreements with the Secretary of Defense for the purpose of 
rendering industrial security services. The following 23 departments 
and agencies have entered into such agreements: (1) National 
Aeronautics and Space Administration, (2) Department of Commerce, (3) 
General Services Administration, (4) Department of State, (5) Small 
Business Administration, (6) National Science Foundation, (7) 
Department of the Treasury, (8) Department of Transportation, (9) 
Department of the Interior, (10) Department of Agriculture, (11) 
Department of Labor, (12) Environmental Protection Agency, (13) 
Department of Justice, (14) Federal Reserve System, (15) Government 
Accountability Office, (16) U.S. Trade Representative, (17) U.S. 
International Trade Commission, (18) U.S. Agency for International 
Development, (19) Nuclear Regulatory Commission, (20) Department of 
Education, (21) Department of Health and Human Services, (22) 
Department of Homeland Security, and (23) Federal Communications 
Commission. 

[9] GAO, Homeland Security: Federal Efforts Are Helping to Alleviate 
Some Challenges Encountered by State and Local Information Fusion 
Centers, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-35] 
(Washington, D.C.: Oct. 30, 2007). Since the attacks of September 11, 
2001, 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. 

[10] GAO, Maritime Security: Observations on Selected Aspects of the 
SAFE Port Act, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-
754T] (Washington, D.C.: Apr. 26, 2007). 

[11] Pub. L. No. 109-347, 120 Stat. 1884 (2006). 

[12] OMB, Report of the Security Clearance Oversight Group Consistent 
with Title III of the Intelligence Reform and Terrorism Prevention Act 
of 2004 (February 2007). 

[13] OMB, Report of the Security Clearance Oversight Group Consistent 
with Title III of the Intelligence Reform and Terrorism Prevention Act 
of 2004 (February 2008). 

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

[15] This committee is led by OMB's Deputy Director for Management and 
is comprised of representatives from DOD, DHS, the Departments of 
Energy, Justice, Transportation, Commerce, and State, the Director of 
National Intelligence, the National Security Council, and the National 
Archives and Records Administration. 

[16] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-352T]. 

[17] GAO, DOD Personnel: Inadequate Personnel Security Investigations 
Pose National Security Risks, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO/NSIAD-00-12] (Washington, D.C.: Oct. 27, 1999). 

[18] 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). 

[19] GAO, DOD Personnel Clearances: Improved Annual Reporting Would 
Enable More Informed Congressional Oversight, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-350] (Washington, D.C.: Feb. 
13, 2008). 

[20] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-350]. 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Mail or Phone: 

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to: 

U.S. Government Accountability Office: 
441 G Street NW, Room LM: 
Washington, D.C. 20548: 

To order by Phone: 
Voice: (202) 512-6000: 
TDD: (202) 512-2537: 
Fax: (202) 512-6061: 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: [email protected]: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, [email protected]: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, [email protected]: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: 

*** End of document. ***