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United States Government Accountability Office: 
GAO: 

Testimony: 

Before the Committee on Homeland Security and Governmental Affairs, 
U.S. Senate: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT: 
Thursday, October 31, 2013: 

Personnel Security Clearances: 

Full Development and Implementation of Metrics Needed to Measure 
Quality of Process: 

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

GAO-14-157T: 

GAO Highlights: 

Highlights of GAO-14-157T, a testimony before the Committee on 
Homeland Security and Governmental Affairs, U.S. Senate. 

Why GAO Did This Study: 

A high-quality personnel security clearance process is necessary to 
minimize the associated risks of unauthorized disclosures of 
classified information and to help ensure that information about 
individuals with criminal activity or other questionable behavior is 
identified and assessed as part of the process for granting or 
retaining clearances. Personnel security clearances allow individuals 
access to classified information that, through unauthorized 
disclosure, can in some cases cause exceptionally grave damage to U.S. 
national security. In 2012, the DNI reported that more than 4.9 
million federal government and contractor employees held or were 
eligible to hold a security clearance. GAO has reported that the 
federal government spent over $1 billion to conduct background 
investigations (in support of security clearances and suitability 
determinations—the consideration of character and conduct for federal 
employment) in fiscal year 2011. 

This testimony addresses the (1) overall security clearance process, 
including roles and responsibilities; and (2) extent that executive 
branch agencies have metrics to help determine the quality of the 
security clearance process. This testimony is based on GAO work issued 
between 2008 and 2013 on DOD’s personnel security clearance program 
and governmentwide suitability and security clearance reform efforts. 
As part of that work, GAO (1) reviewed statutes, federal guidance, and 
processes, (2) examined agency data on the timeliness and quality of 
investigations and adjudications, (3) assessed reform efforts, and (4) 
reviewed samples of case files for DOD personnel. 

What GAO Found: 

Multiple executive branch agencies are responsible for different steps 
of the multi-phased personnel security clearance process that 
includes: determination of whether a position requires a clearance, 
application submission, investigation, and adjudication. Agency 
officials must first determine whether a federal civilian position 
requires access to classified information. The Director of National 
Intelligence (DNI) and the Office of Personnel Management (OPM) are in 
the process of issuing a joint revision to the regulations guiding 
this step in response to GAO’s 2012 recommendation that the DNI issue 
policy and guidance for the determination, review, and validation of 
requirements. After an individual has been selected for a federal 
civilian position that requires a personnel security clearance and the 
individual submits an application for a clearance, investigators-—
often contractors—-from OPM conduct background investigations for most 
executive branch agencies. Adjudicators from requesting agencies use 
the information from these investigations and consider federal 
adjudicative guidelines to determine whether an applicant is eligible 
for a clearance. Further, individuals are subject to reinvestigations 
at intervals that are dependent on the level of security clearance. 
For example, top secret and secret clearance holders are to be 
reinvestigated every 5 years and 10 years, respectively. 

Executive branch agencies have not fully developed and implemented 
metrics to measure quality throughout the personnel security clearance 
process. For more than a decade, GAO has emphasized the need to build 
and monitor quality throughout the personnel security clearance 
process to promote oversight and positive outcomes such as maximizing 
the likelihood that individuals who are security risks will be 
scrutinized more closely. For example, GAO reported in May 2009 that, 
with respect to initial top secret clearances adjudicated in July 2008 
for the Department of Defense (DOD), documentation was incomplete for 
most of OPM’s investigative reports. GAO independently estimated that 
87 percent of about 3,500 investigative reports that DOD adjudicators 
used to make clearance eligibility decisions were missing some 
required documentation, such as the verification of all of the 
applicant’s employment. GAO also estimated that 12 percent of the 
3,500 reports did not contain the required personal subject interview. 
In 2009, GAO recommended that OPM measure the frequency with which its 
investigative reports met federal investigative standards in order to 
improve the quality of investigation documentation. As of August 2013, 
however, OPM had not implemented this recommendation. GAO’s 2009 
report also identified issues with the quality of DOD adjudications. 
Specifically, GAO estimated that 22 percent of about 3,500 initial top 
secret clearances that were adjudicated favorably did not contain all 
the required documentation. As a result, in 2009 GAO recommended that 
DOD measure the frequency with which adjudicative files meet 
requirements. In November 2009, DOD issued a memorandum that 
established a tool called the Review of Adjudication Documentation 
Accuracy and Rationales (RADAR) to measure the frequency with which 
adjudicative files meet the requirements of DOD regulation. According 
to a DOD official, RADAR had been used in fiscal year 2010 to evaluate 
some adjudications, but was not used in fiscal year 2011 due to 
funding shortfalls. DOD restarted the use of RADAR in fiscal year 2012. 

View [hyperlink, http://www.gao.gov/products/GAO-14-157T]. For more 
information, contact Brenda S. Farrell at (202) 512-3604 or 
FarrellB@gao.gov. 

[End of section] 

Chairman Carper, Ranking Member Coburn, and Members of the Committee: 

Thank you for the opportunity to be here to participate in this 
discussion of the federal government's process for personnel security 
clearances. A high-quality personnel security clearance process is 
necessary to minimize the associated risks of unauthorized disclosures 
of classified information and to help ensure that information about 
individuals with criminal activity or other questionable behavior is 
identified and assessed as part of the process for granting or 
retaining clearances. However, recent events, such as unauthorized 
disclosures of classified information, have shown that there is more 
work to be done by federal agencies to help ensure the process 
functions effectively and efficiently, so that only trustworthy 
individuals obtain and keep security clearances and the resulting 
access to classified information that clearances make possible. 

As you know, we have an extensive body of work on issues related to 
the personnel security clearance process going back over a decade. 
Since 2008, we have focused on the government-wide effort to reform 
the security clearance process. Personnel security clearances allow 
government and industry personnel (contractors) to gain access to 
classified information that, through unauthorized disclosure, can in 
some cases cause exceptionally grave damage to U.S. national security. 
It is important to keep in mind that security clearances allow for 
access to classified information on a need to know basis. Federal 
agencies also use other processes and procedures to determine if an 
individual should be granted access to certain government buildings or 
facilities or be employed as either a military, federal civilian 
employee, or contractor for the federal government. Separate from, but 
related to, personnel security clearances are determinations of 
suitability that the executive branch uses to ensure individuals are 
suitable, based on character and conduct, for federal employment in 
their agency or position. 

The federal government processes a high volume of personnel security 
clearances at significant costs. In 2012, the Director of National 
Intelligence (DNI) reported that more than 4.9 million federal 
government and contractor employees held or were eligible to hold a 
security clearance, which poses a formidable challenge to those 
responsible for deciding who should be granted a clearance. 
Furthermore, the federal government spent over $1 billion to conduct 
more than 2 million background investigations (in support of both 
personnel security clearances and suitability determinations for 
government employment outside of the intelligence community) in fiscal 
year 2011. The Department of Defense (DOD) accounts for the majority 
of all personnel security clearances--which includes 788,000 
background investigations that cost over $787 million in fiscal year 
2011.[Footnote 1] 

My testimony today will focus on two topics related to personnel 
security clearances. First, I will discuss the overall personnel 
security clearance process, including roles and responsibilities for 
investigations and adjudications. Second, I will discuss the extent 
that executive branch agencies have developed and implemented metrics 
to help determine the quality of the security clearance process. 

My testimony is based on our reports and testimonies issued from 2008 
through 2013 on DOD's personnel security clearance program and 
government-wide suitability and security clearance reform efforts. A 
list of these related products appears at the end of my statement. As 
part of the work for these products, we reviewed statutes, federal 
guidance and processes, examined agency data on the timeliness and 
quality of investigations and adjudications, assessed reform efforts, 
and reviewed a sample of investigative and adjudication files for DOD 
personnel. The work upon which this testimony is based was conducted 
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 obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. Further 
details about the scope and methodology can be found in each of these 
related products. 

The Overall Personnel Security Clearance Process: 

Multiple executive-branch agencies have key roles and responsibilities 
for different steps of the federal government's personnel security 
clearance process. For example, in 2008, Executive Order 13467 
[Footnote 2] designated the DNI as the Security Executive Agent. As 
such, the DNI is responsible for developing policies and procedures to 
help ensure the effective, efficient, and timely completion of 
background investigations and adjudications relating to determinations 
of eligibility for access to classified information and eligibility to 
hold a sensitive position. In turn, executive branch agencies 
determine which of their positions--military, civilian, or private-
industry contractors--require access to classified information and, 
therefore, which people must apply for and undergo a personnel 
security clearance investigation. Investigators--often contractors--
from Federal Investigative Services within the Office of Personnel 
Management (OPM)[Footnote 3] conduct these investigations for most of 
the federal government using federal investigative standards and OPM 
internal guidance as criteria for collecting background information on 
applicants.[Footnote 4] OPM provides the resulting investigative 
reports to the requesting agencies for their internal adjudicators, 
who use the information along with the federal adjudicative guidelines 
to determine whether an applicant is eligible for a personnel security 
clearance. DOD is OPM's largest customer, and its Under Secretary of 
Defense for Intelligence (USD(I)) is responsible for developing, 
coordinating, and overseeing the implementation of DOD policy, 
programs, and guidance for personnel, physical, industrial, 
information, operations, chemical/biological, and DOD Special Access 
Program security. Additionally, the Defense Security Service, under 
the authority, direction, and control of USD(I), manages and 
administers the DOD portion of the National Industrial Security 
Program[Footnote 5] for the DOD components and other federal agencies 
by agreement, as well as providing security education and training, 
among other things. 

Section 3001 of the Intelligence Reform and Terrorism Prevention Act 
of 2004[Footnote 6] prompted government-wide suitability and security 
clearance reform. The act required, among other matters, an annual 
report to Congress--in February of each year from 2006 through 2011--
about progress and key measurements on the timeliness of granting 
security clearances. It specifically required those reports to include 
the periods of time required for conducting investigations and 
adjudicating or granting clearances. However, the Intelligence Reform 
and Terrorism Prevention Act requirement for the executive branch to 
annually report on its timeliness expired in 2011. More recently the 
Intelligence Authorization Act of 2010[Footnote 7] established a new 
requirement that the President annually report to Congress the total 
amount of time required to process certain security clearance 
determinations for the previous fiscal year for each element of the 
Intelligence Community.[Footnote 8] The Intelligence Authorization Act 
of 2010 additionally requires that those annual reports include the 
total number of active security clearances throughout the United 
States government, to include both government employees and 
contractors. Unlike the Intelligence Reform and Terrorism Prevention 
Act of 2004 reporting requirement, the requirement to submit these 
annual reports does not expire. 

In 2007, DOD and the Office of the Director of National Intelligence 
(ODNI) formed the Joint Security Clearance Process Reform Team, known 
as the Joint Reform Team, to improve the security clearance process 
government-wide. In a 2008 memorandum, the President called for a 
reform of the security clearance and suitability determination 
processes and subsequently issued Executive Order 13467,[Footnote 9] 
which in addition to designating the DNI as the Security Executive 
Agent, also designated the Director of OPM as the Suitability 
Executive Agent. Specifically, the Director of OPM, as Suitability 
Executive Agent, is responsible for developing policies and procedures 
to help ensure the effective, efficient, and timely completion of 
investigations and adjudications relating to determinations of 
suitability, to include consideration of an individual's character or 
conduct. Further, the executive order established a Suitability and 
Security Clearance Performance Accountability Council to oversee 
agency progress in implementing the reform vision. Under the executive 
order, this council is accountable to the President for driving 
implementation of the reform effort, including ensuring the alignment 
of security and suitability processes, holding agencies accountable 
for implementation, and establishing goals and metrics for progress. 
The order also appointed the Deputy Director for Management at the 
Office of Management and Budget as the chair of the council.[Footnote 
10] 

Steps in the Personnel Security Clearance Process: 

In the first step of the personnel security clearance process, 
executive branch officials determine the requirements of a federal 
civilian position, including assessing the risk and sensitivity level 
associated with that position, to determine whether it requires access 
to classified information and, if required, the level of access. 
Security clearances are generally categorized into three levels: top 
secret, secret, and confidential.[Footnote 11] The level of 
classification denotes the degree of protection required for 
information and the amount of damage that unauthorized disclosure 
could reasonably be expected to cause to national defense or foreign 
relations. 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 workloads and costs. 
In 2012, we reported that the DNI, as the Security Executive Agent, 
had not provided agencies clearly defined policy and procedures to 
consistently determine if a position requires a security clearance, or 
established guidance to require agencies to review and revise or 
validate existing federal civilian position designations.[Footnote 12] 
We recommended that the DNI issue policy and guidance for the 
determination, review, and validation of requirements, and ODNI 
concurred with those recommendations, stating that it recognized the 
need to issue or clarify policy. Currently, OPM and ODNI are in the 
process of issuing a joint revision to the regulations guiding 
requirements determination. Specifically, according to officials from 
the ODNI, these offices had obtained permission from the President to 
re-issue the federal regulation jointly, drafted the proposed rule, 
and obtained public input on the regulation by publishing it in the 
Federal Register. According to ODNI and OPM officials, they will 
jointly review and address comments and prepare the final rule for 
approval from the Office of Management and Budget. 

Once an applicant is selected for a position that requires a personnel 
security clearance, the applicant must obtain a security clearance in 
order to gain access to classified information. While different 
departments and agencies may have slightly different personnel 
security clearance processes, the phases that follow--application 
submission, investigation, and adjudication--are illustrative of a 
typical process.[Footnote 13] Since 1997, federal agencies have 
followed a common set of personnel security investigative standards 
and adjudicative guidelines for determining whether federal civilian 
workers, military personnel, and others, such as private industry 
personnel contracted by the government, are eligible to hold a 
security clearance. Figure 1 illustrates the steps in the personnel 
security clearance process, which is representative of the general 
process followed by most executive branch agencies and includes 
procedures for appeals and renewals. 

Figure 1: Steps in the Personnel Security Clearance Process: 

[Refer to PDF for image: process illustration] 

Requirements determination: 
Executive branch agencies determine a position’s level of 
sensitivity, which includes consideration of whether or not a position 
requires access to classified information and, if required, the level 
of access. This information helps inform the decision as to whether a 
clearance is needed. Employees in these positions must be able to 
obtain and maintain a security clearance to gain access to classified 
information. 

Position requires security clearance. 

Application: 
If, during the requirements determination phase, an agency determines 
that a position requires a clearance, the employee completes an 
electronic standard form 86 application, which the requesting agency 
sends to the Office of Personnel Management (OPM). 

Employee completes application, agency submits investigation request. 

Investigation: 
OPM’s Federal Investigative Services division-—with a workforce that 
is 25 percent federal investigator staff and 75 percent contract 
investigator staff—-use federal investigative standards and OPM’s 
internal guidance to conduct the investigations. 

OPM, Federal Investigative Services (FIS) conducts background 
investigation[A]: About 25% of FIS workforce is federal staff; about 
75% of FIS workforce is contractor staff; 
Secret checked: Fingerprints, credit, FBI, local law enforcement, 
employment, education and residence. 
Top Secret checked: Subject and reference interviews, Fingerprints, 
credit, FBI, local law enforcement, birth, employment, education, 
residence, and public records such as marriage or bankruptcy. 

Adjudication: 
Adjudicators from the requesting agency use the information from the 
investigative report to determine whether to grant or deny the 
employee eligibility for a security clearance by considering 
guidelines in 13 specific areas that elicit information about (1) 
conduct that could raise security concerns and (2) factors that could 
allay those security concerns and permit granting a clearance. 

On the basis of information in the investigative report, agency 
adjudicator determines eligibility to access classified information 
and either denies or grants the clearance. 

Appeals: 
Adjudicator may decide to deny or revoke existing security clearance. 
In these cases, employee has the right to appeal and must indicate 
intent to appeal to agency adjudicator. Appeals process is dependent 
on employee choice to appeal in person or in writing, and may involve 
agency adjudicators, agency security appeals boards, and the Defense 
Office of Hearings and Appeals. 

If clearance is approved and there is a long term need for access, 
individual is periodically reinvestigated. 

Periodic reinvestigation: 
As long as an individual holding a personnel security clearance 
remains in a position requiring access to classified information, that 
individual is reinvestigated periodically at intervals dependent on 
the level of security clearance. Top secret clearance holders are 
reinvestigated every 5 years and secret clearance holders are 
reinvestigated every 10 years. 

Employee may appeal if agency denies or revokes clearance. 

Source: GAO analysis. 

[A] OPM provides background investigation services to over 100 
executive branch agencies; however, others, including some agencies in 
the Intelligence Community, have been delegated authority from the 
Office of the Director of National Intelligence, OPM, or both, to 
conduct their own background investigations. 

[End of figure] 

During the application submission phase, a security officer from an 
executive branch agency (1) requests an investigation of an individual 
requiring a clearance; (2) forwards a personnel security questionnaire 
(Standard Form 86) using OPM's electronic Questionnaires for 
Investigations Processing (e-QIP) system or a paper copy of the 
Standard Form 86 to the individual to complete; (3) reviews the 
completed questionnaire; and (4) sends the questionnaire and 
supporting documentation, such as fingerprints and signed waivers, to 
OPM or its investigation service provider. 

During the investigation phase, investigators--often contractors--from 
OPM's Federal Investigative Services use federal investigative 
standards and OPM's internal guidance to conduct and document the 
investigation of the applicant. The scope of information gathered in 
an investigation depends on the needs of the client agency and the 
personnel security clearance requirements of an applicant's position, 
as well as whether the investigation is for an initial clearance or a 
reinvestigation to renew a clearance. For example, in an investigation 
for a top secret clearance, investigators gather additional 
information through more time-consuming efforts, such as traveling to 
conduct in-person interviews to corroborate information about an 
applicant's employment and education. However, many background 
investigation types have similar components. For instance, for all 
investigations, information that applicants provide on electronic 
applications are checked against numerous databases. Both secret and 
top secret investigations contain credit and criminal history checks, 
while top secret investigations also contain citizenship, public 
record, and spouse checks as well as reference interviews and an 
Enhanced Subject Interview to gain insight into an applicant's 
character. Table 1 highlights the investigative components generally 
associated with the secret and top secret clearance levels. After OPM, 
or the designated provider, completes the background investigation, 
the resulting investigative report is provided to the adjudicating 
agency. 

Table 1: Information Gathered in Conducting a Typical Investigation to 
Determine Suitability and Eligibility for a Personnel Security 
Clearance: 

Type of information gathered by component: 1. Personnel security 
questionnaire: The reported answers on an electronic SF-85P or SF-86 
form; 
Type of background investigation: Secret: [Check]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 2. Fingerprints: 
Fingerprints submitted electronically or manually; 
Type of background investigation: Secret: [Check]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 3. National agency check: 
Data from Federal Bureau of Investigation, military records, and other 
agencies as required (with fingerprint); 
Type of background investigation: Secret: [Check]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 4. Credit check: Data from 
credit bureaus where the subject lived/worked/attended school for at 
least 6 months; 
Type of background investigation: Secret: [Check]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 5. Local agency checks: 
Data from law enforcement agencies where the subject 
lived/worked/attended school during the past 10 years or--in the case 
of reinvestigations--since the last security clearance investigation; 
Type of background investigation: Secret: [Check]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 6. Date and place of birth: 
Corroboration of information supplied on the personnel security 
questionnaire; 
Type of background investigation: Secret: [Empty]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 7. Citizenship: For 
individuals born outside of the United States, verification of U.S. 
citizenship directly from the appropriate registration authority; 
Type of background investigation: Secret: [Empty]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 8. Education: Verification 
of most recent or significant claimed attendance, degree, or diploma; 
Type of background investigation: Secret: [Check][V]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 9. Employment: Review of 
employment records and interviews with workplace references, such as 
supervisors and coworkers; 
Type of background investigation: Secret: [Check][V]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 10. References: Data from 
interviews with subject-identified and investigator-developed leads; 
Type of background investigation: Secret: [Check][V]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 11. National agency check 
for spouse or cohabitant: Data from Federal Bureau of Investigation, 
military records, and other agencies as required (without fingerprint); 
Type of background investigation: Secret: [Empty]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 12. Former spouse: Data 
from interview(s) conducted with spouse(s) divorced within the last 10 
years or since the last investigation or reinvestigation; 
Type of background investigation: Secret: [Empty]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 13. Neighborhoods: 
Interviews with neighbors and verification of residence through 
records check; 
Type of background investigation: Secret: [Check][V]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 14. Public records: 
Verification of issues, such as bankruptcy, divorce, and criminal and 
civil court cases; 
Type of background investigation: Secret: [Empty]; 
Type of background investigation: Top Secret: [Check]. 

Type of information gathered by component: 15. Enhanced Subject 
Interview: Collection of relevant data, resolution of significant 
issues or inconsistencies; 
Type of background investigation: Secret: [A]; 
Type of background investigation: Top Secret: [Check]. 

Source: DOD and OPM. 

Note: The content and amount of information collected as part of a 
personnel security clearance investigation is dependent on a variety 
of case-specific factors, including the history of the applicant and 
the nature of the position; however, items 1-15 are typically 
collected for the types of investigations indicated. 

V = Components with this notation are checked through a mail voucher 
sent by OPM's Federal Investigative Services. 

[A] The Enhanced Subject Interview was developed by the Joint Reform 
Team and implemented by OPM in 2011 and serves as an in-depth 
discussion between the interviewer and the subject to ensure a full 
understanding of the applicant's information, potential issues, and 
mitigating factors. It is included in a Minimum Background 
Investigation, one type of suitability investigation, and can be 
triggered by the presence of issues in a secret level investigation. 

[End of table] 

During the adjudication phase, adjudicators from the hiring agency 
[Footnote 14] use the information from the investigative report to 
determine whether an applicant is eligible for a security clearance. 
To make clearance eligibility decisions, the adjudication guidelines 
specify that adjudicators consider 13 specific areas that elicit 
information about (1) conduct that could raise security concerns and 
(2) factors that could allay those security concerns and permit 
granting a clearance.[Footnote 15] If a clearance is denied or 
revoked, appeals of the adjudication decision are possible. We have 
work underway to review the process for security revocations. We 
expect to issue a report on this process by spring of 2014. 

Once an individual has obtained a personnel security clearance and as 
long as they remain in a position that requires access to classified 
national security information, that individual is reinvestigated 
periodically at intervals that are dependent on the level of security 
clearance. For example, top secret clearance holders are 
reinvestigated every 5 years, and secret clearance holders are 
reinvestigated every 10 years. Some of the information gathered during 
a reinvestigation would focus specifically on the period of time since 
the last approved clearance, such as a check of local law enforcement 
agencies where an individual lived and worked since the last 
investigation. Further, the Joint Reform Team began an effort to 
review the possibility of continuous evaluations, which would 
ascertain on a more frequent basis whether an eligible employee with 
access to classified information continues to meet the requirements 
for access. Specifically, the team proposed to move from periodic 
review to that of continuous evaluation, meaning annually for top 
secret and similar positions and at least once every five years for 
secret or similar positions, as a means to reveal security-relevant 
information earlier than the previous method, and provide increased 
scrutiny on populations that could potentially represent risk to the 
government because they already have access to classified information. 
The current federal investigative standards state that the top secret 
level of security clearances may be subject to continuous evaluation. 

Full Development and Implementation of Metrics Needed to Determine 
Quality of Personnel Security Clearance Process: 

The executive branch has developed some metrics to assess quality at 
different phases of the personnel security clearance process; however, 
those metrics have not been fully developed and implemented. To 
promote oversight and positive outcomes, such as maximizing the 
likelihood that individuals who are security risks will be scrutinized 
more closely, we have emphasized, since the late 1990s,[Footnote 16] 
the need to build and monitor quality throughout the personnel 
security clearance process. Having assessment tools and performance 
metrics in place is a critical initial step toward instituting a 
program to monitor and independently validate the effectiveness and 
sustainability of corrective measures. However, we have previously 
reported that executive branch agencies have not fully developed and 
implemented metrics to measure quality in key aspects of the personnel 
security clearance process, including: (1) investigative reports; (2) 
adjudicative files; and (3) the reciprocity of personnel security 
clearances, which is an agency's acceptance of a background 
investigation or clearance determination completed by any authorized 
investigative or adjudicative executive branch agency. 

Metrics Not Yet Implemented to Measure Completeness of OPM 
Investigative Reports: 

We have previously identified deficiencies in OPM's investigative 
reports--results from background investigations--but as of August 2013 
OPM had not yet implemented metrics to measure the completeness of 
these reports. OPM supplies about 90 percent of all federal clearance 
investigations, including those for DOD. For example, in May 2009 we 
reported that, with respect to DOD initial top secret clearances 
adjudicated in July 2008, documentation was incomplete for most OPM 
investigative reports. We independently estimated that 87 percent of 
about 3,500 investigative reports that DOD adjudicators used to make 
clearance decisions were missing at least one type of documentation 
required by federal investigative standards. The type of documentation 
most often missing from investigative reports was verification of all 
of the applicant's employment, followed by information from the 
required number of social references for the applicant and complete 
security forms. We also estimated that 12 percent of the 3,500 
investigative reports did not contain a required personal subject 
interview. 

At the time of our 2009 review, OPM did not measure the completeness 
of its investigative reports, which limited the agency's ability to 
explain the extent or the reasons why some reports were incomplete. As 
a result of the incompleteness of OPM's investigative reports on DOD 
personnel, we recommended in May 2009 that OPM measure the frequency 
with which its investigative reports meet federal investigative 
standards, so that the executive branch can identify the factors 
leading to incomplete reports and take corrective actions.[Footnote 17] 

In a subsequent February 2011 report, we noted that OMB, ODNI, DOD, 
and OPM leaders had provided congressional members with metrics to 
assess the quality of the security clearance process, including 
investigative reports and other aspects of the process.[Footnote 18] 
For example, the Rapid Assessment of Incomplete Security Evaluations 
was one tool the executive branch agencies planned to use for 
measuring quality, or completeness, of OPM's background 
investigations.[Footnote 19] However, according to an OPM official in 
June 2012, OPM chose not to use this tool. Instead, OPM opted to 
develop another tool. In following up on our 2009 recommendations, as 
of August 2013, OPM had not provided enough details on its tool for us 
to determine if the tool had met the intent of our 2009 
recommendation, and included the attributes of successful performance 
measures identified in best practices, nor could we determine the 
extent to which the tool was being used. 

OPM also assesses the quality of investigations based on voluntary 
reporting from customer agencies. Specifically, OPM tracks 
investigations that are (1) returned for rework from the requesting 
agency, (2) identified as deficient using a web-based customer 
satisfaction survey, or (3) identified as deficient through 
adjudicator calls to OPM's quality hotline. However, in our past work, 
we have noted that the number of investigations returned for rework is 
not by itself a valid indicator of the quality of investigative work 
because DOD adjudication officials told us that they have been 
reluctant to return incomplete investigations in anticipation of 
delays that would impact timeliness. Further, relying on agencies to 
voluntarily provide information on investigation quality may not 
reflect the quality of OPM's total investigation workload. We are 
beginning work to further review OPM's actions to improve the quality 
of investigations. 

We have also reported that deficiencies in investigative reports 
affect the quality of the adjudicative process. Specifically, in 
November 2010, we reported that agency officials who utilize OPM as 
their investigative service provider cited challenges related to 
deficient investigative reports as a factor that slows agencies' 
abilities to make adjudicative decisions. The quality and completeness 
of investigative reports directly affects adjudicator workloads, 
including whether additional steps are required before adjudications 
can be made, as well as agency costs. For example, some agency 
officials noted that OPM investigative reports do not include complete 
copies of associated police reports and criminal record checks. 
Several agency officials stated that in order to avoid further costs 
or delays that would result from working with OPM, they often choose 
to perform additional steps internally to obtain missing information. 
According to ODNI and OPM officials, OPM investigators provide a 
summary of police and criminal reports and assert that there is no 
policy requiring inclusion of copies of the original records. However, 
ODNI officials also stated that adjudicators may want or need entire 
records as critical elements may be left out. For example, according 
to Defense Office of Hearings and Appeals officials, in one case, an 
investigator's summary of a police report incorrectly identified the 
subject as a thief when the subject was actually the victim. 

DOD Has Taken Steps to Implement Measures to Determine Completeness of 
Adjudicative Files: 

DOD has taken some intermittent steps to implement measures to 
determine the completeness of adjudicative files to address issues 
identified in our 2009 report regarding the quality of DOD 
adjudications. In 2009, we found that some clearances were granted by 
DOD adjudicators even though some required data were missing from the 
OPM investigative reports used to make such determinations. For 
example, we estimated in our 2009 review that 22 percent of the 
adjudicative files for about 3,500 initial top secret clearances that 
were adjudicated favorably did not contain all the required 
documentation, even though DOD regulations require that adjudicators 
maintain a record of each favorable and unfavorable adjudication 
decision and document the rationale for granting clearance eligibility 
to applicants with security concerns revealed during the 
investigation.[Footnote 20] Documentation most frequently missing from 
adjudicative files was the rationale for granting security clearances 
to applicants with security concerns related to foreign influence, 
financial considerations, and criminal conduct. At the time of our 
2009 review, DOD did not measure the completeness of its adjudicative 
files, which limited the agency's ability to explain the extent or the 
reasons why some files are incomplete. 

In 2009, we made two recommendations to improve the quality of 
adjudicative files. First, we recommended that DOD measure the 
frequency with which adjudicative files meet requirements, so that the 
executive branch can identify the factors leading to incomplete files 
and include the results of such measurement in annual reports to 
Congress on clearances.[Footnote 21] In November 2009, DOD 
subsequently issued a memorandum that established a tool to measure 
the frequency with which adjudicative files meet the requirements of 
DOD regulation. Specifically, the DOD memorandum stated that it would 
use a tool called the Review of Adjudication Documentation Accuracy 
and Rationales, or RADAR, to gather specific information about 
adjudication processes at the adjudication facilities and assess the 
quality of adjudicative documentation. In following up on our 2009 
recommendations, as of 2012, a DOD official stated that RADAR had been 
used in fiscal year 2010 to evaluate some adjudications, but was not 
used in fiscal year 2011 due to funding shortfalls. DOD restarted the 
use of RADAR in fiscal year 2012. 

Second, we recommended that DOD issue guidance to clarify when 
adjudicators may use incomplete investigative reports as the basis for 
granting clearances. In response to our recommendation, DOD's November 
2009 guidance that established RADAR also outlines the minimum 
documentation requirements adjudicators must adhere to when 
documenting personnel security clearance determinations for cases with 
potentially damaging information. In addition, DOD issued guidance in 
March 2010 that clarifies when adjudicators may use incomplete 
investigative reports as the basis for granting clearances. This 
guidance provides standards that can be used for the sufficient 
explanation of incomplete investigative reports. 

Metrics Not Yet Implemented to Measure Clearance Reciprocity: 

While some efforts have been made to develop quality metrics, agencies 
have not yet implemented metrics for tracking the reciprocity of 
personnel security clearances, which is an agency's acceptance of a 
background investigation or clearance determination completed by any 
authorized investigative or adjudicative executive branch agency. 
Although executive branch agency officials have stated that 
reciprocity is regularly granted, as it is an opportunity to save time 
as well as reduce costs and investigative workloads, we reported in 
2010 that agencies do not consistently and comprehensively track the 
extent to which reciprocity is granted government-wide.[Footnote 22] 
ODNI guidance requires, except in limited circumstances, that all 
Intelligence Community elements "accept all in-scope[Footnote 23] 
security clearance or access determinations." Additionally, Office of 
Management and Budget guidance[Footnote 24] requires agencies to honor 
a clearance when (1) the prior clearance was not granted on an interim 
or temporary basis; (2) the prior clearance investigation is current 
and in-scope; (3) there is no new adverse information already in the 
possession of the gaining agency; and (4) there are no conditions, 
deviations, waivers, or unsatisfied additional requirements (such as 
polygraphs) if the individual is being considered for access to highly 
sensitive programs. 

While the Performance Accountability Council has identified 
reciprocity as a government-wide strategic goal, we have found that 
agencies do not consistently and comprehensively track when 
reciprocity is granted, and lack a standard metric for tracking 
reciprocity.[Footnote 25] Further, while OPM and the Performance 
Accountability Council have developed quality metrics for reciprocity, 
the metrics do not measure the extent to which reciprocity is being 
granted. For example, OPM created a metric in early 2009 to track 
reciprocity, but this metric only measures the number of 
investigations requested from OPM that are rejected based on the 
existence of a previous investigation and does not track the number of 
cases in which an existing security clearance was or was not 
successfully honored by the agency. Without comprehensive, 
standardized metrics to track reciprocity and consistent documentation 
of the findings, decision makers will not have a complete picture of 
the extent to which reciprocity is granted or the challenges that 
agencies face when attempting to honor previously granted security 
clearances. 

In 2010, we reported that executive branch officials routinely honor 
other agencies' security clearances, and personnel security clearance 
information is shared between OPM, DOD, and, to some extent, 
Intelligence Community databases.[Footnote 26] However, we found that 
some agencies find it necessary to take additional steps to address 
limitations with available information on prior investigations, such 
as insufficient information in the databases or variances in the scope 
of investigations, before granting reciprocity. For instance, OPM has 
taken steps to ensure certain clearance data necessary for reciprocity 
are available to adjudicators, such as holding interagency meetings to 
determine new data fields to include in shared data. However, we also 
found that the shared information available to adjudicators contains 
summary-level detail that may not be complete. As a result, agencies 
may take steps to obtain additional information, which creates 
challenges to immediately granting reciprocity. 

Further, in 2010 we reported that because there is no government-wide 
standardized training and certification process for investigators and 
adjudicators, according to agency officials, a subject's prior 
clearance investigation and adjudication may not meet the standards of 
the inquiring agency. Although OPM has developed some training, 
security clearance investigators and adjudicators are not required to 
complete a certain type or number of classes. As a result, the extent 
to which investigators and adjudicators receive training varies by 
agency. Consequently, as we have previously reported, agencies are 
reluctant to be accountable for investigations and/or adjudications 
conducted by other agencies or organizations.[Footnote 27] To achieve 
fuller reciprocity, clearance-granting agencies seek to have 
confidence in the quality of prior investigations and adjudications. 

Consequently, we recommended in 2010 that the Deputy Director of 
Management, Office of Management and Budget, in the capacity as Chair 
of the Performance Accountability Council, should develop 
comprehensive metrics to track reciprocity and then report the 
findings from the expanded tracking to Congress. Although OMB agreed 
with our recommendation, a 2011 ODNI report found that Intelligence 
Community agencies experienced difficulty reporting on reciprocity. 
The agencies are required to report on a quarterly basis the number of 
security clearance determinations granted based on a prior existing 
clearance as well as the number not granted when a clearance existed. 
The numbers of reciprocal determinations made and denied are 
categorized by the individual's originating and receiving 
organizational type: (1) government to government, (2) government to 
contractor, (3) contractor to government, and (4) contractor to 
contractor. The report stated that data fields necessary to collect 
the information described above do not currently reside in any of the 
datasets available and the process was completed in an agency 
specific, semi-manual method. Further, the Deputy Assistant Director 
for Special Security of the Office of the Director of National 
Intelligence noted in testimony in June 2012 that measuring 
reciprocity is difficult, and despite an abundance of anecdotes, real 
data is hard to come by. To address this problem, ODNI is developing a 
web-based form for individuals to submit their experience with 
reciprocity issues to the ODNI. According to ODNI, this will allow 
them to collect empirical data, perform systemic trend analysis, and 
assist agencies with achieving workable solutions. 

Sustained Leadership Needed to Fully Develop and Implement Metrics to 
Monitor and Track Quality: 

As previously discussed, DOD accounts for the majority of security 
clearances within the federal government. We initially placed DOD's 
personnel security clearance program on our high-risk list[Footnote 
28] in 2005 because of delays in completing clearances.[Footnote 29] 
It remained on our list until 2011 because of ongoing concerns about 
delays in processing clearances and problems with the quality of 
investigations and adjudications. In February 2011, we removed DOD's 
personnel security clearance program from our high-risk list largely 
because of the department's demonstrated progress in expediting the 
amount of time processing clearances.[Footnote 30] We also noted DOD's 
efforts to develop and implement tools to evaluate the quality of 
investigations and adjudications. 

Even with the significant progress leading to removal of DOD's program 
from our high-risk list, we noted in June 2012 that sustained 
leadership would be necessary to continue to implement, monitor, and 
update outcome-focused performance measures. The initial development 
of some tools and metrics to monitor and track quality not only for 
DOD but government-wide were positive steps; however, full 
implementation of these tools and measures government-wide have not 
yet been realized. While progress in DOD's personnel security 
clearance program resulted in the removal of this area from our high-
risk list, significant government-wide challenges remain in ensuring 
that personnel security clearance investigations and adjudications are 
high-quality. 

In conclusion, oversight of the reform efforts to measure and improve 
the quality of the security clearance process--including background 
investigations--are imperative next steps. Failing to do so increases 
the risk of damaging, unauthorized disclosures of classified 
information. The progress that was made with respect to expediting the 
amount of time processing clearances would not have been possible 
without committed and sustained congressional oversight and the 
leadership of the Performance Accountability Council. Further actions 
are needed now to fully develop and implement metrics to oversee 
quality at every step in the process. Chairman Carper, Ranking Member 
Coburn, this concludes my prepared statement. I would be pleased to 
answer any questions that you or other Members of the Committee may 
have at this time. 

GAO Contacts and Acknowledgment: 

For further information on this testimony, please contact Brenda S. 
Farrell, Director, Defense Capabilities and Management, who may be 
reached at (202) 512-3604 or farrellb@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this statement. GAO staff who made key contributions 
to this testimony include Lori Atkinson (Assistant Director), 
Darreisha Bates, Renee Brown, John Van Schaik, and Michael Willems. 

[End of section] 

Related GAO Products: 

Personnel Security Clearances: Further Actions Needed to Improve the 
Process and Realize Efficiencies. [hyperlink, 
http://www.gao.gov/products/GAO-13-728T]. Washington, D.C.: June 20, 
2013. 

Managing for Results: Agencies Should More Fully Develop Priority 
Goals under the GPRA Modernization Act. [hyperlink, 
http://www.gao.gov/products/GAO-13-174]. Washington, D.C.: April 19, 
2013. 

Security Clearances: Agencies Need Clearly Defined Policy for 
Determining Civilian Position Requirements. [hyperlink, 
http://www.gao.gov/products/GAO-12-800]. Washington, D.C.: July 12, 
2012. 

Personnel Security Clearances: Continuing Leadership and Attention Can 
Enhance Momentum Gained from Reform Effort. [hyperlink, 
http://www.gao.gov/products/GAO-12-815T]. Washington, D.C.: June 21, 
2012. 

2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 
Fragmentation, Achieve Savings, and Enhance Revenue. [hyperlink, 
http://www.gao.gov/products/GAO-12-342SP]. Washington, D.C.: February 
28, 2012. 

Background Investigations: Office of Personnel Management Needs to 
Improve Transparency of Its Pricing and Seek Cost Savings. [hyperlink, 
http://www.gao.gov/products/GAO-12-197]. Washington, D.C.: February 
28, 2012. 

GAO's 2011 High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-11-394T]. Washington, D.C.: February 
17, 2011. 

High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-11-278]. Washington, D.C.: February 
16, 2011. 

Personnel Security Clearances: Overall Progress Has Been Made to 
Reform the Governmentwide Security Clearance Process. [hyperlink, 
http://www.gao.gov/products/GAO-11-232T]. Washington, D.C.: December 
1, 2010. 

Personnel Security Clearances: Progress Has Been Made to Improve 
Timeliness but Continued Oversight Is Needed to Sustain Momentum. 
[hyperlink, http://www.gao.gov/products/GAO-11-65]. Washington, D.C.: 
November 19, 2010. 

DOD Personnel Clearances: Preliminary Observations on DOD's Progress 
on Addressing Timeliness and Quality Issues. [hyperlink, 
http://www.gao.gov/products/GAO-11-185T]. Washington, D.C.: November 
16, 2010. 

Personnel Security Clearances: An Outcome-Focused Strategy and 
Comprehensive Reporting of Timeliness and Quality Would Provide 
Greater Visibility over the Clearance Process. [hyperlink, 
http://www.gao.gov/products/GAO-10-117T]. Washington, D.C.: October 1, 
2009. 

Personnel Security Clearances: Progress Has Been Made to Reduce Delays 
but Further Actions Are Needed to Enhance Quality and Sustain Reform 
Efforts. [hyperlink, http://www.gao.gov/products/GAO-09-684T]. 
Washington, D.C.: September 15, 2009. 

Personnel Security Clearances: An Outcome-Focused Strategy Is Needed 
to Guide Implementation of the Reformed Clearance Process. [hyperlink, 
http://www.gao.gov/products/GAO-09-488]. Washington, D.C.: May 19, 
2009. 

DOD Personnel Clearances: Comprehensive Timeliness Reporting, Complete 
Clearance Documentation, and Quality Measures Are Needed to Further 
Improve the Clearance Process. [hyperlink, 
http://www.gao.gov/products/GAO-09-400]. Washington, D.C.: May 19, 
2009. 

High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-09-271]. Washington, D.C.: January 
2009. 

Personnel Security Clearances: Preliminary Observations on Joint 
Reform Efforts to Improve the Governmentwide Clearance Eligibility 
Process. [hyperlink, http://www.gao.gov/products/GAO-08-1050T]. 
Washington, D.C.: July 30, 2008. 

Personnel Clearances: Key Factors for Reforming the Security Clearance 
Process. [hyperlink, http://www.gao.gov/products/GAO-08-776T]. 
Washington, D.C.: May 22, 2008. 

Employee Security: Implementation of Identification Cards and DOD's 
Personnel Security Clearance Program Need Improvement. [hyperlink, 
http://www.gao.gov/products/GAO-08-551T]. Washington, D.C.: April 9, 
2008. 

Personnel Clearances: Key Factors to Consider in Efforts to Reform 
Security Clearance Processes. [hyperlink, 
http://www.gao.gov/products/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/products/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/products/GAO-08-350]. Washington, D.C.: February 
13, 2008. 

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

High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/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/products/GAO-06-1070]. Washington, D.C.: September 
28, 2006. 

DOD Personnel Clearances: New Concerns Slow Processing of Clearances 
for Industry Personnel. [hyperlink, 
http://www.gao.gov/products/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/products/GAO-06-747T]. Washington, D.C.: May 17, 
2006. 

DOD Personnel Clearances: Government Plan Addresses Some Long-standing 
Problems with DOD's Program, But Concerns Remain. [hyperlink, 
http://www.gao.gov/products/GAO-06-233T]. Washington, D.C.: November 
9, 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/products/GAO-05-842T]. 
Washington, D.C.: June 28, 2005. 

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

DOD Personnel Clearances: Preliminary Observations Related to Backlogs 
and Delays in Determining Security Clearance Eligibility for Industry 
Personnel. [hyperlink, http://www.gao.gov/products/GAO-04-202T]. 
Washington, D.C.: May 6, 2004. 

[End of section] 

Footnotes: 

[1] GAO, Background Investigations: Office of Personnel Management 
Needs to Improve Transparency of Its Pricing and Seek Cost Savings, 
[hyperlink, http://www.gao.gov/products/GAO-12-197] (Washington, D.C.: 
Feb. 28, 2012). 

[2] Executive Order No. 13467, Reforming Processes Related to 
Suitability for Government Employment, Fitness for Contractor 
Employees, and Eligibility for Access to Classified National Security 
Information (June 30, 2008). 

[3] OPM's Federal Investigative Services employs both federal and 
contract investigators to conduct work required to complete background 
investigations. The federal staff constitutes about 25 percent of that 
workforce, while OPM currently also has contracts for investigative 
fieldwork with several investigation firms, constituting the remaining 
75 percent of its investigative workforce. 

[4] In 2005, the Office of Management and Budget designated OPM as the 
agency responsible for, among other things, the day-to-day supervision 
and monitoring of security clearance investigations, and for tracking 
the results of individual agency-performed adjudications, subject to 
certain exceptions. However, the Office of the Director of National 
Intelligence can designate other agencies as an "authorized 
investigative agency" pursuant to 50 U.S.C. § 3341(b)(3), as 
implemented through Executive Order 13467. Alternatively, under 5 
U.S.C. § 1104(a)(2), OPM can redelegate any of its investigative 
functions subject to performance standards and a system of oversight 
prescribed by OPM under 5 U.S.C. § 1104(b). Agencies without delegated 
authority rely on OPM to conduct their background investigations while 
agencies with delegated authority--including the Defense Intelligence 
Agency, National Security Agency, National Geospatial-Intelligence 
Agency, Central Intelligence Agency, Federal Bureau of Investigation, 
National Reconnaissance Office, and Department of State--have been 
authorized to conduct their own background investigations. 

[5] The National Industrial Security Program was established by 
Executive Order 12829 to safeguard Federal Government classified 
information that is released to contractors, licensees, and grantees 
of the United States Government. Executive Order 12829, National 
Industrial Security Program (Jan. 6, 1993, as amended). 

[6] Pub. L. No. 108-458 (2004) (relevant sections codified at 50 
U.S.C. § 3341). 

[7] Pub. L. No. 111-259, § 367 (2010) (codified at 50 U.S.C. § 3104). 

[8] This timeliness reporting requirement applies only to the elements 
of the Intelligence Community; it does not cover non-intelligence 
agencies that were covered by the reporting requirements in the 
Intelligence Reform and Terrorism Prevention Act of 2004. 

[9] Executive Order No. 13467, Reforming Processes Related to 
Suitability for Government Employment, Fitness for Contractor 
Employees, and Eligibility for Access to Classified National Security 
Information (June 30, 2008). 

[10] The Performance Accountability Council is comprised of the 
Director of National Intelligence as the Security Executive Agent, the 
Director of OPM as the Suitability Executive Agent, and the Deputy 
Director for Management, Office of Management and Budget, as the chair 
with the authority to designate officials from additional agencies to 
serve as members. As of June 2012, the council included 
representatives from the Departments of Defense, Energy, Health and 
Human Services, Homeland Security, State, Treasury, and Veterans 
Affairs, and the Federal Bureau of Investigation. 

[11] A top secret clearance is generally also required for access to 
Sensitive Compartmented Information--classified intelligence 
information concerning or derived from intelligence sources, methods, 
or analytical processes that is required to be protected within formal 
access control systems established and overseen by the Director of 
National Intelligence. 

[12] GAO, Security Clearances: Agencies Need Clearly Defined Policy 
for Determining Civilian Position Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-12-800] (Washington, D.C.: July 12, 
2012). 

[13] The general process for performing a background investigation for 
either a secret or top secret clearance is the same; however, the 
level of detail and types of information gathered for a top secret 
clearance is more substantial than a secret clearance. 

[14] For industry personnel, the Defense Security Service (DSS) 
adjudicated clearance eligibility for DOD and 24 other federal 
agencies, by agreement, using OPM-provided investigative reports. 
However, DOD is in the process of consolidating its adjudication 
facilities, including those for industry personnel. Per DOD 5220.22-M, 
National Industrial Security Program: Operating Manual (Feb. 28, 2006 
incorporating changes Mar. 28, 2013), those agencies are: (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; (23) Federal Communications 
Commission; and (24) Office of Personnel Management. 

[15] Federal guidelines state that clearance decisions require a 
common sense determination of eligibility for access to classified 
information based upon careful consideration of the following 13 
areas: allegiance to the United States; foreign influence; foreign 
preference; sexual behavior; personal conduct; financial 
considerations; alcohol consumption; drug involvement; emotional, 
mental, and personality disorders; criminal conduct; security 
violations; outside activities; and misuse of information technology 
systems. Further, the guidelines require adjudicators to evaluate the 
relevance of an individual's overall conduct by considering factors 
such as the nature, extent, and seriousness of the conduct; the 
circumstances surrounding the conduct, to include knowledgeable 
participation; the frequency and recency of the conduct; and the 
individual's age and maturity at the time of the conduct, among others. 

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

[17] GAO, DOD Personnel Clearances: Comprehensive Timeliness 
Reporting, Complete Clearance Documentation, and Quality Measures Are 
Needed to Further Improve the Clearance Process, [hyperlink, 
http://www.gao.gov/products/GAO-09-400] (Washington, D.C.: May 19, 
2009). 

[18] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: Feb. 2011). 

[19] The Rapid Assessment of Incomplete Security Evaluations tool was 
developed by DOD to track the quality of investigations conducted by 
OPM for DOD personnel security clearance investigations, measured as a 
percent of investigations completed that contained deficiencies. 

[20] DOD Regulation 5200.2-R, DOD Personnel Security Program (Jan. 
1987, incorporating changes Feb. 23, 1996). 

[21] GAO, DOD Personnel Clearances: Comprehensive Timeliness 
Reporting, Complete Clearance Documentation, and Quality Measures Are 
Needed to Further Improve the Clearance Process, [hyperlink, 
http://www.gao.gov/products/GAO-09-400] (Washington, D.C.: May 19, 
2009). 

[22] In addition to establishing objectives for timeliness, the 
Intelligence Reform and Terrorism Prevention Act of 2004 established 
requirements for reciprocity, which is an agency's acceptance of a 
background investigation or clearance determination completed by any 
authorized investigative or adjudicative executive branch agency, 
subject to certain exceptions such as completing additional 
requirements like polygraph testing. Further, in October 2008, ODNI 
issued guidance on the reciprocity of personnel security clearances. 
ODNI, Intelligence Community Policy Guidance 704.4, Reciprocity of 
Personnel Security Clearance and Access Determinations (Oct. 2, 2008). 

[23] Although there are broad federal investigative guidelines, the 
details and depth of an investigation varies by agency depending upon 
its mission. 

[24] Office of Management and Budget, Memorandum for Deputies of 
Executive Departments and Agencies: Reciprocal Recognition of Existing 
Personnel Security Clearances (Dec. 12, 2005); Office of Management 
and Budget, Memorandum for Deputies of Executive Departments and 
Agencies: Reciprocal Recognition of Existing Personnel Security 
Clearances (July 17, 2006). 

[25] GAO, Personnel Security Clearances: Progress Has Been Made to 
Improve Timeliness but Continued Oversight Is Needed to Sustain 
Momentum, [hyperlink, http://www.gao.gov/products/GAO-11-65] 
(Washington, D.C.: Nov. 19, 2010). 

[26] [hyperlink, http://www.gao.gov/products/GAO-11-65]. 

[27] GAO, Personnel Clearances: Key Factors to Consider in Efforts to 
Reform Security Clearance Processes, [hyperlink, 
http://www.gao.gov/products/GAO-08-352T] (Washington, D.C.: Feb. 27, 
2008). 

[28] Every two years at the start of a new Congress, GAO issues a 
report that identifies government operations that are high risk due to 
their vulnerabilities to fraud, waste, abuse, and mismanagement, or 
are most in need of transformation to address economy, efficiency, or 
effectiveness. 

[29] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-05-207] (Washington, D.C.: Jan. 1, 
2005). 

[30] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: Feb. 2011). 

[End of section] 

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