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entitled 'Questions for the Record Related to DOD's Personnel Security 
Clearance Program and the Government Plan for Improving the Clearance 
Process' which was released on January 17, 2006. 

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January 17, 2006: 

The Honorable George V. Voinovich: 
The Honorable Daniel K. Akaka: 
Ranking Minority Member: 
Subcommittee on Oversight of Government Management, the Federal 
Workforce, and the District of Columbia: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Subject: Questions for the Record Related to DOD's Personnel Security 
Clearance Program and the Government Plan for Improving the Clearance 

On November 9, 2005, I testified before your subcommittee at a hearing 
on "Access Delayed: Fixing the Security Clearance Process, Part II." 
This letter responds to three questions for the record that Senator 
Daniel K. Akaka posed. The questions and my responses follow. 

1. The Government Accountability Office (GAO) in testimony before this 
Subcommittee in September 2004 and June 2005, indicated that the Office 
of Personnel Management (OPM) continues to use its investigations 
contractor to conduct personnel security clearance investigations for 
the contractor's employees even though GAO raised an internal control 
concern about this practice during its 1996 review. Would you please 
elaborate on these concerns, and describe whether you believe OPM has 
taken sufficient steps to addressing the internal control and quality- 
control problems identified by GAO? 

Although we have evidence that OPM has not taken steps to correct the 
cited internal control weakness that we identified nearly a decade ago, 
conclusions about the sufficiency of OPM's specific quality control 
procedures must wait until we complete other work requested by this 
subcommittee and others. When OPM was privatizing its investigative 
function in 1996, we identified an internal control concern--OPM's 
investigations contractor was conducting personnel security clearance 
investigations on its own employees.[Footnote 1] The February 2005 
transfer of the Department of Defense's (DOD) federal investigators to 
OPM resulted in OPM again having federal investigators available to 
correct this internal control weakness, but OPM has not yet used the 
federal investigators for that purpose.[Footnote 2] OPM officials have, 
however, indicated that they plan to have the federal investigators 
perform the personnel security clearance investigations of contract 
investigators starting in March 2006. If OPM follows through with this 
plan, it would correct the cited internal control weakness. 

We have begun work requested by this subcommittee and others to obtain 
up-to-date information on the sufficiency of the specific procedures 
that OPM uses to monitor the quality of the investigative reports that 
it provides to its customers. Our examination of quality control 
procedures will include observing the training that investigators 
receive, conducting a site visit to OPM's investigations processing 
center to review the step-by-step process used to monitor quality, and 
reviewing a sample of the investigative reports that DOD adjudication 
facilities have used to determine eligibility for a security clearance. 

2. Does GAO have a position on the use and measurement of timeliness 
for closed-pending investigative reports? 

In our February 2004 report, we noted that OPM's issuance of closed 
pending cases--investigations sent to adjudication facilities without 
one or more types of source data--causes ambiguity in defining and 
accurately estimating the backlog.[Footnote 3] In our October 1999 
report examining the completeness of clearance investigations supplied 
by DOD's Defense Security Service, we noted that risks to national 
security are posed when investigations do not fully comply with federal 
standards.[Footnote 4] To lessen the risk associated with incomplete 
investigative reports, we recommended DOD adjudication facility 
officials grant clearances only when all essential investigative work 
has been done. Adjudication facility officials said that they were 
reluctant to return incomplete investigations for further investigation 
because they were concerned about additional delays. 

In fiscal year 2002 (the last year for which we have data), about 10 
percent of the 283,480 DOD cases fully closed by OPM were initially 
delivered to DOD adjudication facilities as closed pending cases. When 
measuring the timeliness of its contractors' performance, OPM defined 
completed investigations as cases that (1) have the complete 
information required for the type of investigation, (2) are closed 
pending, or (3) have been discontinued. If the investigations have not 
been fully completed, we believe that closed pending cases should be 
included in the investigative portion of the backlog. 

3. What are some of the primary criteria that GAO uses to determine 
whether or not to remove a program from its high-risk list, and what is 
needed for security clearances to be off the list? 

In order for DOD's personnel security clearance program to be removed 
from our high-risk list, the program must address (1) the general 
criteria outlined in our fiscal year 2001 report and (2) the many 
recommendations that we have provided specific to DOD's program. In our 
2001 report, we identified the following general criteria that are 
considered in designating and removing programs from our high-risk 
list:[Footnote 5] 

* a demonstrated strong commitment and top leadership support to 
address the risk(s); 

* the capacity (that is, the people and other resources) to resolve the 

* a corrective action plan that defines the root causes, identifies 
effective solutions, and provides for substantially completing 
corrective measures in the near term, including but not limited to 
steps necessary to implement solutions we have recommended; 

* a program instituted to monitor and independently validate the 
effectiveness and sustainability of corrective measures; and: 

* the ability to demonstrate progress in having implemented corrective 

Before removing the security clearance process from our high-risk list, 
we must determine whether DOD has satisfied all of the criteria we have 
established for removing a high-risk designation. As noted in our 
November 2005 testimony,[Footnote 6] DOD must undertake many corrective 
actions to implement our recommendations and to correct previously 
identified problems before its personnel security clearance program can 
be removed from our high-risk list. Perseverance by the administration 
in implementing our recommended solutions regarding the personnel 
security clearance process and continued oversight and action by 
Congress are both essential. When actions, including those in response 
to our recommendations, result in significant progress toward resolving 
a high-risk problem, we will remove the high-risk designation. 

If you or other members of the subcommittee have any additional 
questions about DOD's personnel security program, please contact me at 
(202) 512-5559 or Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this correspondence. GAO staff who made major contributions to 
the correspondence are listed in the enclosure. 

Sincerely yours, 

Signed by: 

Derek B. Stewart: 
Director, Defense Capabilities and Management: 

Enclosure: GAO Contact and Staff Acknowledgments: 

GAO Contact: Derek B. Stewart, (202) 512-5559 or 


In addition to the contact above, Jack E. Edwards, Assistant Director, 
Kurt A. Burgeson, David Epstein, Sara Hackley, William J. Rigazio, and 
Jennifer Young made key contributions to this correspondence. 



[1] See GAO, Privatization of OPM's Investigations Service, GAO/GGD-96- 
97R (Washington, D.C.: Aug. 22, 1996). 

[2] According to OPM officials, these federal investigators are 
currently being used to help reduce the existing backlog of DOD 
security clearance investigations. 

[3] GAO, DOD Personnel Clearances: DOD Needs to Overcome Impediments to 
Eliminating Backlog and Determining Its Size, GAO-04-344 (Washington, 
D.C.: Feb. 9, 2004). 

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

[5] GAO, Determining Performance and Accountability Challenges and High 
Risks, GAO-01-159SP (Washington, D.C.: November 2000). 

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