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entitled 'DOD Personnel Clearances: Questions for the Record Related to 
the Quality and Timeliness of Clearances' which was released on March 
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March 25, 2008: 

The Honorable Solomon P. Ortiz: 
The Honorable J. Randy Forbes: 
Ranking Member: 
Subcommittee on Readiness: 
Committee on Armed Forces: 
House of Representatives: 

Subject: DOD Personnel Clearances: Questions for the Record Related to 
the Quality and Timeliness of Clearances: 

On February 13, 2008, Mr. Jack Edwards--an Acting Director in our 
Defense Capabilities and Management team--testified before your 
subcommittee at a hearing on the Department of Defense (DOD) security 
clearance processes.[Footnote 1] This report responds to your request 
for additional information on that subject. Your questions, and our 
responses, follow. 

1. In the report that GAO issued today to this committee and your 
testimony statement, you discussed a need for more emphasis on quality 
in clearance products and processes. What have agencies been using as 
quality measures, and are they sufficient? 

Through our reports and testimonies, we have emphasized a need to build 
more quality and quality monitoring into the clearances process. As we 
have reported, since 1999 government agencies have relied on a measure 
of quality--the percentage of investigative reports returned by 
requesting agencies to the investigating agency because of 
incompleteness--and this measure is insufficient. We find this measure 
to be problematic because the number of investigations returned for 
rework is not by itself a valid indicator of the quality of 
investigative work. One reason for this is that according to 
adjudication officials, they were reluctant to return incomplete 
investigations in anticipation of further delays.[Footnote 2] 
Additionally, this metric pertains only to the investigation phase of 
the clearance process, and there are no metrics for the other five 
phases of the investigative process (the clearance process has six 
phases: the requirements setting, application-submission, 
investigation, adjudication, appeal, and clearance updating). 

2. Do you believe that DOD, OMB, and OPM have made the necessary 
commitment to improve the security clearance process? What steps need 
to be taken to ensure that on-going initiatives continue past this 

As noted in our February 13, 2008 report,[Footnote 3] we are encouraged 
by some department-specific and governmentwide efforts that have 
improved DOD's personnel security clearance program. Examples of 
improvements to the process include (1) DOD's ability to electronically 
submit a clearance applicant's form authorizing the release of medical 
information and (2) a governmentwide effort that has resulted in the 
increased use of the Office of Personnel Management's (OPM) Electronic 
Questionnaires for Investigations Processing. 

In addition, as we have previously reported, we have been encouraged by 
the commitment that the Office of Management and Budget (OMB) and OPM 
have demonstrated in the development of a governmentwide plan to 
address clearance-related problems.[Footnote 4] The OMB Deputy Director 
met with us to discuss OMB's general strategy for addressing the 
problems that led to our high-risk designation for DOD's clearance 
program. Demonstrating strong management commitment and top leadership 
support to address a known risk is one of the requirements for us to 
remove DOD's clearance program from our high-risk list. 

Nevertheless, as we noted in our February 13, 2008 statement, we have 
identified a number of challenges in our past work that will require 
long-term commitment from this and subsequent administrations to 
further improve the security clearance process. Specifically, in our 
statement we emphasized the need for initiative in five areas: (1) 
improvement in projecting future industry investigation needs, (2) 
eliminating delays in the clearance processes, (3) supplementing the 
limited information on quality of clearance products and procedures, 
(4) increasing the amount of clearance-related funding information 
available to Congress to improve oversight, and (5) developing and 
implementing a department-specific plan to address clearance 
problems.[Footnote 5] 

In another recent testimony,[Footnote 6] we emphasized that current and 
future efforts to reform personnel security clearance processes should 
consider, among other things, the following four key factors: (1) 
determining whether clearances are required for a specific position, 
(2) incorporating quality control steps throughout the clearance 
processes, (3) establishing metrics for assessing all aspects of 
clearance processes, and (4) providing Congress with the long-term 
funding requirements of security clearance reform. 

3. The Intel Reform Act requires that timeliness statistics be reported 
to Congress. Do the timeliness statistics provide a full picture of how 
quickly clearances are being issued? If there are additional statistics 
that would add to the Congress's oversight of clearance timeliness, 
what types of factors should be considered in identifying additional 

The timeliness statistics that OMB and OPM have provided to Congress 
may not convey the full magnitude of the time required to complete 
clearance investigations and adjudications. In May 2007, we reported 
the following five concerns with the transparency of the government's 
timeliness statistics: (1) limited information on reinvestigations for 
clearance updating, (2) not counting the total number of days to finish 
the application-submission phase, (3) shifting some investigation- 
related days to the adjudication phase or not counting them, (4) not 
counting the total number of days to complete closed pending cases, and 
(5) not counting the total number of days to complete investigations 
sent back for rework.[Footnote 7] Our preliminary observations of OMB's 
February 2008 Report of the Security Clearance Oversight Group and 
recent OPM congressional testimony indicate that there may be 
continuing problems in these areas. 

* Limited information on reinvestigations for clearance updating: In 
previous OMB reports and OPM congressional testimony, the government 
provided limited information on the time to complete reinvestigations. 
However, OMB included in its 2008 Report of the Security Clearance 
Oversight Group information on the timeliness of reinvestigations. 

* Not counting the total number of days to finish the application- 
submission phase: Our preliminary observations of OMB's February 2008 
report raise concerns that some activities occurring in the initial 
part of the application-submission phase may not be included when 
counting the time to complete the application-submission phase. For 
example, OMB's February 2008 report noted that investigation timeliness 
was "calculated from receipt of the full request for investigation;" 
however, some activities may be excluded in timeliness measurements 
depending on how OMB interprets the "full request for investigation." 

* Shifting some investigation-related days to the adjudication phase or 
not counting them: In our September 2006 report, we raised concerns 
about how the time to complete the adjudication phase was measured 
because OMB included mailing time in reporting the timeliness of the 
adjudication phase.[Footnote 8] This practice continues as noted in 
OMB's February 2008 report to Congress: timeliness statistics for 
adjudications "include... up to 15 days in mail and handling between 
OPM and the adjudicating agency." Including time to mail and handle 
investigative reports from OPM to adjudicating agencies shifts a 
portion of the time to complete the investigation to the adjudication 

* Not counting the total number of days to complete closed pending 
cases: OPM may be combining two kinds of investigations, which may 
overstate the timeliness of completed investigations. In her February 
13, 2008, congressional testimony statement, the Associate Director in 
charge of OPM's investigations unit did not indicate whether the 
investigation timeliness statistics presented in her statement included 
closed pending investigations in the calculation of the average times 
to complete all investigations. Closed pending investigations are 
investigative reports sent to adjudication facilities without one or 
more types of source data required by the federal investigative 
standards. In our February 2004 report, we noted that closed pending 
cases should continue to be tracked separately in the investigations 
phase of the clearance process because a closed pending investigation 
may be reopened when the missing data are supplied. The time 
measurement of a closed pending case is suspended for an undetermined 
amount of time, which is not accounted for if the pending cases are 
reopened later and included in the timeliness calculations of fully 
completed investigations. 

Not counting the total number of days to complete investigations sent 
back for rework: In 2006, we reported that in instances when 
investigative reports are returned to OPM to address investigative 
insufficiencies, OPM's procedure has been to replace the investigative 
time recorded for providing the initial report to the adjudication 
agency with the investigation time to rework the report to address the 
insufficiencies. Reworking the investigative report could take less 
time than the earlier effort to complete the initial investigative 
report. While reworking cases occurs approximately in 1 to 2 percent of 
investigative reports, replacing the initial investigative time with 
the time to complete the reworked investigations as the total number of 
days to complete investigations does not provide a full picture of how 
quickly clearances are being issued. OMB's February 2008 report does 
not clarify its timeliness statistics to show how or if it is 
addressing this issue. 

Finally, during the hearing, each of the panel members was asked to 
respond for the record to a series of questions about a database that 
may record statistics on the reciprocity of clearances. Specifically, 
we were asked which government agency is maintaining a database that 
records instances of nonreciprocity, what agencies have the most cases 
of nonreciprocity, how many waivers were granted in the last year, and 
why such information about reciprocity was not provided in OMB's annual 
report to Congress. We are not aware of a database maintained by any 
government agency that records information on reciprocity. 

If you or other members of the subcommittee have any additional 
questions about DOD's personnel security clearance processes, please 
contact Brenda S. Farrell at (202) 512-3604 or In 
addition, contact points for our Offices of Congressional Relations and 
Public Affairs may be found on the last page of this correspondence. 
GAO staff members who made major contributions to this correspondence 
are listed in the enclosure. 

Signed by: 

Brenda S. Farrell: 

Director, Defense Capabilities and Management: 


[End of section] 

Enclosure I: GAO Contact and Staff Acknowledgments: 

GAO Contact: Brenda S. Farrell, (202) 512-3604 or 

Acknowledgments: In addition to the contact above, Jack E. Edwards, 
Acting Director; David E. Moser, Assistant Director; Grace Coleman; 
James P. Klein; Ron La Due Lake; Oscar Mardis; and Karen Thornton, made 
key contributions to this correspondence. 

[End of section] 


[1] GAO, DOD Personnel Clearances: DOD Faces Multiple Challenges in Its 
Efforts to Improve Clearance Processes for Industry Personnel, GAO-08- 
470T (Washington, D.C.: Feb. 13, 2008). 

[2] For example, GAO, DOD Personnel Clearances: Additional OMB Actions 
Are Needed to Improve the Security Clearance Process, GAO-06-1070 
(Washington, D.C.: Sept. 28, 2006); DOD Personnel Clearances: 
Government Plan Addresses Some Long-standing Problems with DOD's 
Program, But Concerns Remain, GAO-06-233T (Washington, D.C.: Nov. 9, 
2005); and DOD Personnel: Inadequate Personnel Security Investigations 
Pose National Security Risks, GAO/NSIAD-00-12 (Washington, D.C.: Oct. 
27, 1999). 

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

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

[5] GAO-08-470T. 

[6] GAO, Personnel Clearances: Key Factors to Consider in Efforts to 
Reform Security Clearance Processes, GAO-08-352T (Washington, D.C.: 
Feb. 27, 2008). 

[7] GAO, DOD Personnel Clearances: Delays and Inadequate Documentation 
Found for Industry Personnel, GAO-07-842T (Washington, D.C.: May 17, 

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

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