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Testimony: 

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

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT:
Thursday, October 1, 2009: 

Personnel Security Clearances: 

An Outcome-Focused Strategy and Comprehensive Reporting of Timeliness 
and Quality Would Provide Greater Visibility over the Clearance 
Process: 

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

GAO-10-117T: 

[End of section] 

Madam Chairwoman, Ranking Member Myrick, and Members of the 
Subcommittee: 

Thank you for the opportunity to be here to discuss the key findings in 
two reports that we recently released on the personnel security 
clearance process.[Footnote 1] As you know, we conducted our review of 
personnel security clearance reforms in response to a request from the 
Chairman of the House Permanent Select Committee on Intelligence and 
you, Madam Chairwoman. We conducted a separate review on the existing 
personnel security clearance process within the Department of Defense 
(DOD) under the authority of the Comptroller General.[Footnote 2] This 
is the third in a series of hearings in which you have asked GAO to 
testify; and this Subcommittee's oversight has helped focus attention 
on the need for security clearance reform.[Footnote 3] 

Personnel security clearances are used to verify that national security 
information--which in some cases could cause exceptionally grave damage 
to U.S. national defense or foreign relations if disclosed--is 
entrusted only to individuals who have proven reliability and loyalty 
to the nation. Following the terrorist attacks on September 11, 2001, 
the nation's defense and intelligence needs grew, prompting increased 
demand for personnel with security clearances. According to officials 
from the Joint Reform Team,[Footnote 4] about 2.4 million people-- 
excluding some of those with clearances who work in areas of national 
intelligence--currently hold clearances, and the Office of Personnel 
Management (OPM) conducted about 750,000 national security 
investigations in fiscal year 2008. We have previously reported on 
delays and backlogs in security clearance processing, lack of 
reciprocity[Footnote 5] among agencies, and incomplete investigations. 
As a result of these long-standing issues, we have designated the 
Department of Defense's (DOD) personnel security clearance program a 
high-risk area since 2005.[Footnote 6] 

In response to concerns about delays in processing clearances and other 
issues, Congress, including the House Permanent Select Committee on 
Intelligence, set goals and established requirements for improving the 
clearance process in the Intelligence Reform and Terrorism Prevention 
Act of 2004 (IRTPA).[Footnote 7] Those requirements include, among 
other things, improving the timeliness of the clearance process, 
achieving interagency reciprocity, establishing an integrated database 
to track investigative and adjudicative information,[Footnote 8] and 
evaluating available technology for investigations and adjudications. 
IRTPA also requires the executive branch to provide a report to 
Congress, by February 15 of each year, on the progress made during the 
preceding year toward meeting IRTPA's requirements for security 
clearances, including the length of time agencies take to complete 
investigations and adjudications, a discussion of impediments to the 
implementation of IRTPA's requirements, and any other information or 
recommendations the executive branch considers appropriate.[Footnote 9] 
While DOD and other executive branch agencies responsible for 
investigating and adjudicating clearances for federal personnel, 
military servicemembers, and government contractors have made 
significant progress toward improving the timeliness of the clearance 
process and evaluating the use of available technology in clearance 
processing, problems related to the quality of clearance investigations 
and adjudication determinations and in the use of information 
technology persist. 

The Joint Reform Team was established to coordinate efforts to achieve 
IRTPA timeliness goals and improve the processes related to granting 
security clearances and determining suitability for government 
employment.[Footnote 10] In its April 2008 report, the Joint Reform 
Team called for an executive branch governance structure to ensure 
accountability and sustain reform momentum. In addition to the April 
2008 report, the Joint Reform Team has provided two other key reports, 
which collectively communicate the reform effort's plans for reforming 
the security clearance process. First, in December 2008, the Joint 
Reform Team issued a report on the progress of the reform efforts and 
provided further details on the plans to implement reforms. Most 
recently, in March 2009, the Joint Reform Team finalized an Enterprise 
Information Technology Strategy to support the reformed security and 
suitability process and its associated milestones described in the 
April and December reports. Figure 1 highlights key events related to 
security clearance reform. 

Figure 1: Key Events Related to the Security Clearance Reform Efforts: 

[Refer to PDF for image: timeline] 

December 17, 2004: 
Intelligence Reform and Terrorist Prevention Act passed. 

January 2005: 
Government Accountability Office places Department of Defense’s 
clearance program on its high-risk list. 

June 27, 2005: 
Executive Order 13881 designates Office of Management and Budget the 
single entity to ensure centralization, uniformity, and reciprocity of 
security clearance policies. 

November 2005: 
Office of Management and Budget issues a plan for improving the 
security clearance process. 

June 25, 2007: 
The Joint Reform Team is formed to develop a plan for clearance reform, 
including research priorities and an information technology strategy, 
to achieve IRTPA goals. 

April 30, 2008: 
The Joint Reform Team issues a report on reforming the security 
clearance and suitability process. 

June 30, 2008: 
Executive Order 13467 establishes the Performance Accountability 
Council to drive implementation of the reform effort and designated the 
Office of Management and Budget's Deputy Director for Management as 
Chair. 

December 18, 2008: 
The Joint Reform Team issues a report outlining reform progress and 
further plans. 

March 17, 2009: 
The Joint Reform Team issues an Enterprise Information Technology 
Strategy to support the reformed security and suitability process. 

Source: GAO analysis. 

[End of figure] 

My statement today will highlight the key recommendations from the two 
reports we recently released, which include (1) the need for a fully 
developed strategic framework for the reform process that includes 
outcome-focused performance measures to show progress and (2) more 
transparency in annually reporting to Congress on the timeliness and 
quality of the clearance process. My statement is based on our review 
of the Joint Reform Team's plans, as well as our work on DOD's security 
clearance process, which includes reviews of clearance-related files 
and interviews of senior officials at the Office of Management and 
Budget (OMB), DOD, Office of the Director of National Intelligence 
(ODNI), and OPM. In addition, this statement is based on key practices 
and implementation steps for mergers and organizational 
transformations.[Footnote 11] 

We conducted our work on both reports between March 2008 and May 2009 
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. 

Initial Reform Efforts Have Partially Aligned with Key Practices but 
Lack a Fully Developed Strategic Framework with Outcome-Focused 
Performance Measures to Show Progress: 

Initial joint reform efforts have, in part, aligned with key practices 
that we have identified for organizational transformations, such as 
having committed leadership and a dedicated implementation team, but 
reports issued by the Joint Reform Team do not provide a strategic 
framework that contains other important elements of a successful 
transformation, such as a mission statement and long-term goals with 
related outcome-focused performance measures to show progress, and do 
not identify obstacles to progress and possible remedies. In September 
2002, GAO convened a forum to identify and discuss practices and 
lessons learned from major private and public sector organizational 
mergers, acquisitions, and transformations that can serve to guide 
federal agencies as they transform their processes in response to 
governance challenges. Consistent with some of these key practices, in 
June 2008 Executive Order 13467 established the Suitability and 
Security Clearance Performance Accountability Council, commonly known 
as the Performance Accountability Council, as the head of the 
governmentwide governance structure responsible for achieving reform 
goals, driving implementation, and overseeing clearance reform efforts. 
The Deputy Director for Management at OMB--who was confirmed in June 
2009--serves as the chair of the council. The Executive Order also 
designated Executive Agents for Suitability and Security.[Footnote 12] 
The Joint Reform Team, while not formally part of the governance 
structure established by Executive Order 13467, works under the council 
to provide progress reports to the President, recommend research 
priorities, and oversee the development and implementation of an 
information technology strategy, among other things. Membership on this 
council currently includes senior executive leaders from 11 federal 
agencies. In addition to high-level leadership, the reform effort has 
benefited from a dedicated implementation team--the Joint Reform Team--
to manage the transformation process from the beginning.[Footnote 13] 

Although the high-level leadership and governance structure of the 
current reform effort distinguish it from previous efforts, it is 
difficult to gauge progress of reform, or determine if corrective 
action is needed, because the council, through the Joint Reform Team, 
has not established a method for evaluating the progress of the reform 
efforts. Without a strategic framework that fully addresses the long- 
standing security clearance problems and incorporates key practices for 
transformation--including the ability to demonstrate progress leading 
to desired results--the Joint Reform Team is not in a position to 
demonstrate to decision makers the extent of progress that it is making 
toward achieving its desired outcomes, and the effort is at risk of 
losing momentum and not being fully implemented. 

In addition to the key practices, the personnel security clearance 
joint reform reports that we reviewed collectively also have begun to 
address essential factors for reforming the security clearance process, 
which represents positive steps. GAO's prior work and IRTPA identified 
several factors key to reforming the clearance process. These include 
(1) developing a sound requirements determination process, (2) engaging 
in governmentwide reciprocity, (3) building quality into every step of 
the process, (4) consolidating information technology, and (5) 
identifying and reporting long-term funding requirements.[Footnote 14] 
However, the Joint Reform Team's information technology strategy, which 
is intended to be a cross-agency collaborative initiative, does not yet 
define roles and responsibilities for implementing a new automated 
capability. GAO's prior work has stressed the importance of defining 
these roles and responsibilities when initiating cross-agency 
initiatives.[Footnote 15] Also, the joint reform reports do not contain 
any information on initiatives that will require funding, determine how 
much they will cost, or identify potential funding sources. Without 
long-term funding requirements, decision makers in both the executive 
and legislative branches will lack important information for comparing 
and prioritizing proposals for reforming the clearance processes. The 
reform effort's success will be dependent upon the extent to which the 
Joint Reform Team is able to fully address these key factors moving 
forward. 

Therefore, we recommended that the OMB Deputy Director of Management, 
in the capacity as Chair of the Performance Accountability Council, 
ensure that the appropriate entities--such as the Performance 
Accountability Council, its subcommittees, or the Joint Reform Team-- 
establish a strategic framework for the joint reform effort to include 
(1) a mission statement and strategic goals; (2) outcome-focused 
performance measures to continually evaluate the progress of the reform 
effort toward meeting its goals and addressing long-standing problems 
with the security clearance process; (3) a formal, comprehensive 
communication strategy that includes consistency of message and 
encourages two-way communication between the Performance Accountability 
Council and key stakeholders; (4) a clear delineation of roles and 
responsibilities for the implementation of the information technology 
strategy among all agencies responsible for developing and implementing 
components of the information technology strategy; and (5) long-term 
funding requirements for security clearance reform, including estimates 
of potential cost savings from the reformed process that are 
subsequently provided to decision makers in Congress and the executive 
branch. 

In oral comments on our report, OMB stated that it partially concurred 
with our recommendation to establish a strategic framework for the 
joint reform effort. Further, in written agency comments provided to us 
jointly by DOD and ODNI, they also partially concurred with our 
recommendation. Additionally, DOD and ODNI commented on the specific 
elements of the strategic framework that we included as part of our 
recommendation. For example, in their comments, DOD and ODNI agreed 
that the reform effort must contain outcome-focused performance 
measures, but added that these metrics must evolve as the process 
improvements and new capabilities are developed and implemented because 
the effort is iterative and in phased development. We continue to 
believe that outcome-focused performance measures are a critical tool 
that can be used to guide the reform effort and allow overseers to 
determine when the reform effort has accomplished its goals and 
purpose. In addition, DOD and ODNI asserted that considerable work has 
already been done on information technology for the reform effort, but 
added that even clearer roles and responsibilities will be identified 
moving forward. Regarding our finding that, at present, no single 
database exists in accordance with IRTPA's requirement that OPM 
establish an integrated database that tracks investigations and 
adjudication information, DOD and ODNI stated that the reform effort 
continues its iterative implementation of improvements to systems that 
improve access to information that agencies need. They also 
acknowledged that more work needs to be done to identify long-term 
funding requirements. 

Executive Branch Reporting Does Not Provide Congress Full Visibility 
over Timeliness or Quality of Clearances: 

While our work also found that DOD and OPM met timeliness requirements 
for personnel security clearances in fiscal year 2008, the executive 
branch's 2009 required report to Congress does not reflect the full 
range of time it takes to make all initial clearance decisions. 
Currently, 80 percent of initial clearance decisions are to be made 
within 120 days, on average, and by December 2009 a plan is to be 
implemented under which to the extent practical 90 percent of initial 
clearance decisions are to be made within 60 days, on average. Under 
both requirements, the executive branch can exclude the slowest 
percentile, and then report on an average of the remaining clearances. 
The most recent report stated that the average time to complete the 
fastest 90 percent of initial clearances for military and DOD civilians 
in fiscal year 2008 was 124 days, on average. However, without taking 
averages or excluding the slowest clearances, we analyzed 100 percent 
of initial clearances granted in 2008 and found that 39 percent still 
took more than 120 days. By limiting its reporting on timeliness to the 
average of the fastest 90 percent of the initial clearance decisions 
made in fiscal year 2008, the executive branch did not provide 
congressional decision makers with visibility over the full range of 
time it takes to make all initial clearance decisions and the reasons 
why delays continue to exist. 

In addition to limited visibility over timeliness of clearances, the 
executive branch's annual reports to Congress on the personnel security 
clearance process have provided decision makers with limited data on 
quality, and the executive branch has missed opportunities to make the 
clearance process transparent to Congress. For example, we 
independently estimated that 87 percent[Footnote 16] of about 3,500 
investigative reports prepared by OPM that DOD adjudicators (employees 
who decide whether to grant a clearance to an applicant based on the 
investigation and other information) used to make clearance decisions, 
for initial top secret clearances adjudicated in July 2008, were 
missing required documentation. We found, however, that DOD has not 
issued formal guidance clarifying if and under what circumstances 
adjudicators can adjudicate incomplete investigative reports. For DOD 
adjudicative files, we estimated that 22 percent[Footnote 17] were 
missing required documentation of the rationale for granting clearances 
to applicants with security concerns. Because neither OPM nor DOD 
measures the completeness of their investigative reports or 
adjudicative files, both agencies are limited in their ability to 
explain the extent to which or the reasons why some documents are 
incomplete. Incomplete documentation may lead to increases in the time 
needed to complete the clearance process and in the overall costs of 
the process and may reduce the assurance that appropriate safeguards 
are in place to prevent DOD from granting clearances to untrustworthy 
individuals. We have stated that timeliness alone does not provide a 
complete picture of the clearance process and emphasized that attention 
to quality could increase reciprocity--accepting another federal 
entity's clearances--and the executive branch, though not required to 
include information on quality in its annual reports, has latitude to 
report appropriate information. We are encouraged that, while the 2009 
report did not provide any data on quality, unlike previous reports it 
did identify quality metrics that the executive branch proposes to 
collect. 

Because the executive branch has not fully addressed quality or the 
full range of time to complete clearances in its reports, it has missed 
opportunities to provide congressional decision makers with full 
transparency over the clearance process. Therefore, in our recent 
report, we recommended that the Deputy Director for Management at OMB, 
as the Chair of the Performance Accountability Council, include (1) 
comprehensive data on the timeliness of the personnel security 
clearance process and (2) metrics on quality in future versions of the 
IRTPA-required annual report to Congress. We also recommended that DOD 
clarify its guidance to specify when adjudicators can use incomplete 
investigative reports in adjudication decisions and that OPM and DOD 
measure the completeness of their investigation and adjudication 
documentation to improve the completeness of future documentation. In 
commenting on a draft of our report, OMB concurred with both of our 
recommendations to that agency, commenting that it recognized the need 
for more reporting on timeliness and quality. OMB described some steps 
that the Performance Accountability Council is taking to address our 
recommendations, including developing measures to account, more 
comprehensively, for the time it takes to complete the end-to-end 
clearance process. In its written comments, DOD also concurred with 
both of the recommendations directed to the department, and described 
specific steps it expects to implement later this year to address the 
recommendations. Finally, in its written comments, OPM did not indicate 
whether it concurred with the one recommendation we made to that 
agency. Instead, OPM highlighted improvements it has made in reducing 
delays in the clearance investigations process since DOD transferred 
this function to OPM in 2005. 

Concluding Observations: 

In my statement, I have highlighted recommendations from the two 
reports we recently released that, if implemented, will help the 
responsible agencies continue to guide the security clearance reform 
effort and improve the clearance process. We are encouraged that the 
Joint Reform Team's efforts during the past year have included several 
actions to improve the process, and we recognize that OPM and DOD are 
currently meeting IRTPA timeliness requirements, which represents 
significant and noteworthy progress. At the request of your 
Subcommittee, we will continue to monitor ongoing joint reform efforts 
with a focus on reciprocity and information technology advances, as 
well as efforts by the responsible agencies to implement our related 
recommendations, and we will continue to assess the impact of those 
efforts on the security clearance process governmentwide. Although the 
high-level leadership and governance structure of the current reform 
effort distinguish it from previous attempts at clearance reform, it is 
important to note that, in June 2009 the administration confirmed a 
vital leadership component necessary for sustaining the momentum 
achieved to date. OMB's new Deputy Director for Management will play a 
crucial role in deciding how to implement the recommendations contained 
in the reports we recently released, as well as prior recommendations 
on this issue, and in leading the reform effort in his role as chair of 
the Performance Accountability Council. 

Madam Chairwoman, this concludes my prepared statement. I would be 
happy to respond to any questions that you or members of the 
Subcommittee may have at this time. 

GAO Contact and Staff Acknowledgments: 

For further information about this testimony, please contact Brenda S. 
Farrell, Director, Defense Capabilities and Management, at (202) 512- 
3604, or farrellb@gao.gov. Key contributors to this statement include 
David Moser (Assistant Director), Lori Atkinson, Joseph M. Capuano, 
Sara Cradic, Susan Ditto, Cindy Gilbert, Shvetal Khanna, James P. 
Klein, Greg Marchand, Shannin O'Neil, and Sarah Veale. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this testimony. 

[End of section] 

Related GAO Products: 

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 22, 
2009. 

DOD Personnel Clearances: Preliminary Observations about Timeliness and 
Quality. [hyperlink, http://www.gao.gov/products/GAO-09-261R]. 
Washington, D.C.: December 19, 2008. 

Personnel Security Clearance: 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: 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. 

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: 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/products/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/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. 

[End of section] 

Footnotes: 

[1] GAO, 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) and 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). 

[2] This report discusses: (1) reporting on timeliness of processing 
DOD clearances, (2) completeness of the documentation for making 
initial top-secret clearance decisions for DOD personnel, and (3) 
reporting of the quality of the clearance process. 

[3] GAO testified before this Subcommittee in February and July 2008 
(see [hyperlink, http://www.gao.gov/products/GAO-08-352T] and 
[hyperlink, http://www.gao.gov/products/GAO-08-1050T]). In the past 2 
years, GAO has also testified on concerns with the timeliness of the 
security clearance process, among other things, before (1) the 
Subcommittee on Oversight of Government Management, the Federal 
Workforce, and the District of Columbia of the Senate Committee on 
Homeland Security and Governmental Affairs, (2) the Subcommittee on 
Government Management, Organization, and Procurement, House Committee 
on Oversight and Government Reform, and (3) the Subcommittee on 
Readiness, House Committee on Armed Services. 

[4] The Joint Reform Team--which currently consists of cognizant 
entities within the Office of Management and Budget, Office of 
Personnel Management, Office of the Director of National Intelligence, 
and Department of Defense--was established in 2007 by the Director of 
National Intelligence and the Under Secretary of Defense (Intelligence) 
through a Memorandum of Agreement to execute personnel security 
clearance joint reform efforts. 

[5] Reciprocity is an agency's acceptance of a background investigation 
or clearance determination completed by another authorized 
investigative or adjudicative agency. 

[6] GAO, High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-05-207] (Washington, D.C.: January 
2005); High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-07-310] (Washington, D.C.: January 
2007); and High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January 
2009). 

[7] Pub. L. No. 108-458, § 3001 (2004). 

[8] The security clearance process currently consists of six phases: 
requirements setting, application submission, investigation, 
adjudication, appeal, and renewal. 

[9] On January 22, 2009, Representative Anna Eshoo, Chairwoman of the 
Subcommittee on Intelligence Community Management, House Permanent 
Select Committee on Intelligence, introduced H.R. 639, the "Security 
Clearance Oversight and Accountability Act." H.R. 639 would require 
additional annual reports to Congress, including identifying how many 
security clearances completed during the previous year took longer than 
1 year to complete and the causes of significant delays in the 
completion of those clearances, and another including metrics for 
adjudication and investigation quality. 

[10] Determinations of suitability for government employment in 
positions in the competitive service and for career appointment in the 
Senior Executive Service include consideration of aspects of an 
individual's character or conduct that may have an impact on the 
integrity or efficiency of their service. Exec. Order No. 13467, 
Reforming Processes Related to Suitability for Government Employment, 
Fitness for Contractor Employees, and Eligibility for Access to 
Classified National Security Information, at § 1.2(l) (June 30, 2008) 
(citing 5 C.F.R. Part 731). 

[11] GAO, Highlights of a GAO Forum: Mergers and Transformation: 
Lessons Learned for a Department of Homeland Security and Other Federal 
Agencies. [hyperlink, http://www.gao.gov/products/GAO-03-293SP] 
(Washington, D.C.: Nov. 14, 2002) and Results- Oriented Cultures: 
Implementation Steps to Assist Mergers and Organizational 
Transformations. [hyperlink, http://www.gao.gov/products/GAO-03-669] 
(Washington, D.C.: July 2, 2003). 

[12] The Director of OPM was designated as the Executive Agent for 
Suitability, and the Director of National Intelligence was designated 
Executive Agent for Security. 

[13] According to the Joint Reform Team, over 70 personnel from DOD, 
OPM, and ODNI currently support its initiatives (including 
approximately 17 full-time staff). 

[14] Establishing a sound requirement-determination process, building 
quality into every step of the process, and providing Congress with 
long-term funding requirements are identified in our previous work. See 
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). Establishing governmentwide reciprocity and developing and 
consolidating information technology are derived from § 3001(d) and (f) 
of IRTPA. 

[15] GAO, Information Technolgoy: Customs Automated Commercial 
Environment Program Progressing, but Need for Management Improvements 
Continues. [hyperlink, http://www.gao.gov/products/GAO-05-267] 
(Washington, D.C.: Mar 14, 2005). 

[16] This estimate has a margin of error, based on a 95 percent 
confidence interval, of +/-9 percent and is based on our review of a 
random sample of 100 OPM-provided investigative reports for initial top 
secret clearances granted in July 2008 by the U.S. Army, U.S. Navy, and 
U.S. Air Force central adjudication facilities. In addition, we 
reviewed the investigative reports for the presence or absence of 
required documentation. Available information often did not allow a 
determination of why the documentation was missing. For example, 
required documentation could be missing because an investigator failed 
to gather the information or to document that the information was 
gathered. In either case, an investigative report would not provide an 
adjudicator with all of the information required by the federal 
investigative standards and OPM's internal guidance. 

[17] This estimate has a margin of error, based on a 95 percent 
confidence interval, of +/-10 percent and is based on our review of a 
random sample of 100 DOD adjudicative files for initial top secret 
clearances granted in July 2008 by the U.S. Army, the U.S. Navy, and 
the U.S. Air Force central adjudication facilities. These adjudicative 
files are associated with the 100 OPM-provided investigative reports we 
reviewed and produced estimates from in the previous analysis about the 
documentation completeness in investigative reports. 

[End of section] 

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