oversight

Security Clearances: Agencies Need Clearly Defined Policy for Determining Civilian Position Requirements

Published by the Government Accountability Office on 2012-07-12.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to the Ranking Member,
             Committee on Homeland Security, House
             of Representatives


July 2012
             SECURITY
             CLEARANCES

             Agencies Need Clearly
             Defined Policy for
             Determining Civilian
             Position Requirements




GAO-12-800
                                                 July 2012

                                                 SECURITY CLEARANCES
                                                 Agencies Need Clearly Defined Policy for
                                                 Determining Civilian Position Requirements
Highlights of GAO-12-800, a report to the
Ranking Member, Committee on Homeland
Security, House of Representatives




Why GAO Did This Study                           What GAO Found
Security clearances allow personnel              The Director of National Intelligence (DNI), as Security Executive Agent, has not
access to classified information that,           provided agencies clearly defined policy and procedures to consistently
through unauthorized disclosure, can,            determine if a position requires a security clearance. Executive Order 13467
in some cases, cause exceptionally               assigns DNI responsibility for, among other things, developing uniform and
grave damage to U.S. national                    consistent policies to determine eligibility for access to classified information, and
security. In 2011, the DNI reported that         gives the DNI authority to issue guidance to agency heads to ensure uniformity in
over 4.8 million federal government              processes relating to those determinations. In the absence of this guidance,
and contractor employees held or were            agencies are using an Office of Personnel Management (OPM) tool that OPM
eligible for a clearance. To safeguard
                                                 designed to determine the sensitivity and risk levels of civilian positions which, in
classified data and manage costs,
                                                 turn, inform the type of investigation needed. OPM audits, however, found
agencies need an effective process to
determine whether civilian positions
                                                 inconsistency in these position designations, and some agencies described
require a clearance. GAO was asked               problems in implementing OPM’s tool. In an April 2012 audit, OPM reviewed the
to examine the extent to which the               sensitivity levels of 39 positions in an agency within the Department of Defense
executive branch has established                 (DOD) and reached different conclusions than the agency for 26 of them.
policies and procedures for agencies to          Problems exist, in part, because OPM and the Office of the Director of National
use when (1) first determining if federal        Intelligence (ODNI) did not collaborate on the development of the position
civilian positions require a security            designation tool, and because their roles for suitability—consideration of
clearance and (2) reviewing and                  character and conduct for federal employment—and security clearance reform
revising or validating existing federal          are still evolving. Without guidance from the DNI, and without collaboration
civilian position security clearance             between the DNI and OPM in future revisions to the tool, executive branch
requirements. GAO reviewed executive             agencies will continue to risk making security clearance determinations that are
orders and the Code of Federal                   inconsistent or at improper levels.
Regulations and met with officials from
ODNI and OPM because of their                    The DNI also has not established guidance to require agencies to review and
Directors’ assigned roles as Security            revise or validate existing federal civilian position designations. Executive Order
and Suitability executive agents, as             12968 says each agency shall request or grant clearance determinations, subject
well as DHS and DOD based on the                 to certain exceptions, based on a demonstrated need for access, and keep to a
volume of clearances they process.               minimum the number of employees that it determines are eligible for access to
                                                 classified information. The order also states that access to classified information
What GAO Recommends                              shall be terminated when an employee no longer has a need for access, and
GAO recommends that the DNI issue                prohibits agencies from requesting or approving eligibility in excess of actual
clearly defined policy for agencies to           requirements for access. During this review of Department of Homeland Security
follow when determining if federal               (DHS) and DOD components, GAO found that agency officials were aware of the
civilian positions require a security            need to keep the number of security clearances to a minimum, but were not
clearance, and that the DNI and                  always required to conduct periodic reviews and validations of the security
Director of OPM collaborate to revise            clearance needs of existing positions. Overdesignating positions results in
the existing position designation tool.          significant cost implications, given that the fiscal year 2012 base price for a top
GAO further recommends that the DNI              secret clearance investigation conducted by OPM is $4,005, while the base price
issue guidance to require agencies to            of a secret clearance is $260. Conversely, underdesignating positions could lead
periodically review and revise or                to security risks. GAO found that the agencies follow varying practices because
validate the designation of their                the DNI has not established guidance that requires executive branch agencies to
existing federal civilian positions. ODNI        review and revise or validate position designations on a recurring basis. Without
and OPM concurred, although OPM                  such a requirement, executive branch agencies may be hiring and budgeting for
raised concerns with which GAO                   initial and periodic security clearance investigations using position descriptions
disagrees and addresses in the report.
                                                 and security clearance requirements that no longer reflect national security
View GAO-12-800. For more information,           needs. Further, since reviews are not done consistently, DHS and DOD and
contact Brenda S. Farrell at (202) 512-3604 or   other executive branch agencies cannot have assurances that they are keeping
farrellb@gao.gov
                                                 the number of positions that require security clearances to a minimum.
                                                                                           United States Government Accountability Office
Contents


Letter                                                                                            1
                       Background                                                                 4
                       The Executive Branch Has Not Issued Clearly Defined Policy
                         Guidance for Determining When a Federal Civilian Position
                         Needs a Security Clearance                                             10
                       The Executive Branch Does Not Have a Consistent Process for
                         Reviewing and Validating Existing Security Clearance
                         Requirements for Civilian Positions                                    16
                       Conclusions                                                              20
                       Recommendations for Executive Action                                     20
                       Agency Comments and Our Evaluation                                       21

Appendix I             Scope and Methodology                                                    26



Appendix II            Position Designation Guidance                                            30



Appendix III           Personnel Security Clearance Process                                     35



Appendix IV            Comments from the Office of the Director of National Intelligence        37



Appendix V             Comments from the Office of Personnel Management                         40



Appendix VI            Comments from the Department of Homeland Security                        45



Appendix VII           GAO Contact and Staff Acknowledgments                                    46



Related GAO Products                                                                            47




                       Page i                                         GAO-12-800 Security Clearances
Tables
          Table 1: Executive Branch Agencies and Offices Interviewed                                27
          Table 2: Summary of Selected DHS and DOD Position Designation
                   Guidance                                                                         30


Figures
          Figure 1: DHS and DOD Security Clearance Determination Process
                   for Federal Civilian Positions                                                    7
          Figure 2: Seven-Step Process for Suitability and Security Clearance
                   Reform                                                                            9




          Abbreviations

          Office of the Director of National Intelligence (ODNI)
          Department of Defense (DOD)
          Department of Homeland Security (DHS)
          Office of Personnel Management (OPM)
          Single Scope Background Investigation (SSBI)
          Access National Agency Check and Inquiries (ANACI)
          Moderate Risk Background Investigation (MBI)
          Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA)
          Director of National Intelligence (DNI)
          Office of Management and Budget (OMB)
          Sensitive Compartmented Information (SCI)




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          Page ii                                                    GAO-12-800 Security Clearances
United States Government Accountability Office
Washington, DC 20548




                                   July 12, 2012

                                   The Honorable Bennie G. Thompson
                                   Ranking Member
                                   Committee on Homeland Security
                                   House of Representatives


                                   Dear Mr. Thompson:

                                   Personnel security clearances allow government personnel to gain
                                   access to classified information that, through unauthorized disclosure,
                                   can in some cases cause exceptionally grave damage to U.S. national
                                   security. The September 11, 2001, attacks spurred an increase in the
                                   number of positions that require a security clearance across the executive
                                   branch. In tracking the number of people that have a security clearance,
                                   the Office of the Director of National Intelligence (ODNI) reported that as
                                   of October 1, 2011, over 4.8 million federal government civilian workforce,
                                   military personnel, and contractor employees held or were eligible to
                                   hold 1 a security clearance. 2, 3 This large number of personnel holding
                                   clearances coupled with risks to national security underscore the need for
                                   executive branch agencies to have a standard process to determine
                                   which positions require a security clearance. Additionally, a standard
                                   process is also needed to effectively manage costs, since agencies
                                   spend significant amounts annually on national security and other
                                   background investigations. For example, two of the agencies that grant
                                   the most security clearances, the Department of Defense (DOD) and the
                                   Department of Homeland Security (DHS) spent $787 million and at least




                                   1
                                    In certain cases, individuals are investigated and deemed eligible to hold a security
                                   clearance. These individuals do not have access to classified information. However,
                                   access can be granted when the duties of their position require it.
                                   2
                                    The ODNI report notes that there could be some duplicative entries. However, we did not
                                   verify the accuracy of this number.
                                   3
                                    According to the Office of Personnel Management (OPM) fiscal year 2010 data, the
                                   federal government workforce consisted of over 4.4 million federal civilian employees and
                                   military personnel. This figure does not include contractors.




                                   Page 1                                                      GAO-12-800 Security Clearances
$57 million, 4 respectively, on suitability 5 and security clearance
background investigations in fiscal year 2011.

In our previous work, 6 we identified the need for a sound requirements
determination process to be considered in executive branch efforts to
reform the security clearance process. Determining the requirements of a
federal position includes assessing both the risk and sensitivity level
associated with a position, which includes consideration of whether that
position requires access to classified information. Specifically, we noted
that the executive branch could address whether the numbers and levels
of security clearances are appropriate and examine existing policies and
practices to see if they need to be updated or otherwise modified.
Developing a sound requirements process is important because requests
for clearances for positions that do not need a clearance or need a lower
level of clearance increase investigative workload and costs
unnecessarily. For example, we reported in 2008 that changing the
clearance needed for a position from secret to top secret increases the
investigative workload for that one position about 20-fold. That is, top
secret clearances must be performed twice as often as secret clearances
(every 5 years versus 10 years) and require 10 times as many
investigative staff hours (about 60 versus 6). More recently, our 2012
report found that the executive branch spent over $1 billion on
background investigations for suitability and security clearances in fiscal
year 2011. 7 Further, the Office of Personnel Management (OPM)—the
federal investigative service provider for the majority of the executive
branch—experienced an almost 79 percent increase in its reported costs



4
 For DHS, this $57 million represents only the amount that DHS paid OPM for suitability
and security background investigations in 2010. In addition, DHS conducts some of its
own background investigations.
5
 Determinations of suitability for government employment in positions in the competitive
service, certain positions in the excepted service, and for career appointment in the Senior
Executive Service include consideration of aspects of individuals’ character or conduct
that may have an impact on the integrity or efficiency of their service.
6
 GAO, Personnel Clearances: Key Factors for Reforming the Security Clearance Process,
GAO-08-776T (Washington, D.C.: May 22, 2008) and Personnel Clearances: Key Factors
to Consider in Efforts to Reform Security Clearance Processes, GAO-08-352T
(Washington, D.C.: Feb. 27, 2008).
7
 GAO, Background Investigations: Office of Personnel Management Needs to Improve
Transparency of Its Pricing and Seek Cost Savings, GAO-12-197 (Washington, D.C.: Feb.
28, 2012).




Page 2                                                     GAO-12-800 Security Clearances
to conduct background investigations between fiscal years 2005 and
2011. Specifically, OPM’s reported costs increased from about $602
million in fiscal year 2005 to almost $1.1 billion in fiscal year 2011 (in
fiscal year 2011 dollars).

You asked us to evaluate federal government policies and practices for
identifying positions that require security clearances, and analyze whether
a uniform, consistent, and effective security clearance requirements
determination process is in place. In response to this request, we
examined the extent to which the executive branch has established
(1) policies and procedures for agencies to use when first determining
whether federal civilian positions require a security clearance and
(2) policies and procedures for agencies to review and revise or validate
existing federal civilian position security clearance requirements.

Specifically, the scope of our work focused on the security clearance
requirements of federal civilian positions from selected components within
DHS and DOD, due to the volume of clearances that these two agencies
process. Within DHS, selected components included the U.S. Coast
Guard, U.S. Immigration and Customs Enforcement, and the
Transportation Security Administration. Within DOD, selected
components included the headquarters-level elements of the
Departments of the Army, the Navy, the Air Force, and Washington
Headquarters Services, which provides human capital support for several
nonservice DOD agencies and activities. For our first objective, to
examine the extent to which the executive branch has established
policies and procedures for agencies to use when first determining
whether federal civilian positions require a security clearance, we
interviewed key officials from the above-mentioned federal departments
and selected components, as well as OPM and ODNI. In addition, we
reviewed relevant Executive Orders including 10450, 12968, and 13467, 8




8
 Executive Order No. 10450, Security Requirements for Government Employment (Apr.
27, 1953 as amended), Executive Order No. 12968, Access to Classified Information
(Aug. 2, 1995 as amended), 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).




Page 3                                                   GAO-12-800 Security Clearances
             Joint Reform Team 9 reports, and part 732 of Title 5 of the Code of
             Federal Regulations. 10 We also obtained and analyzed personnel security
             clearance policies within DHS, DOD, and the selected components within
             these departments. Further, we obtained and analyzed OPM’s position
             designation tool because agencies we spoke with use the tool in the
             position designation process. For our second objective, to examine the
             extent to which the executive branch has policies and procedures for
             agencies to review and revise or validate existing federal civilian position
             security clearance requirements, we held meetings with knowledgeable
             officials from DHS, DOD, OPM, and ODNI. In addition, we reviewed part
             732 of Title 5 of the Code of Federal Regulations. We also analyzed
             DHS’s and DOD’s personnel security policies, and the applicable policies
             of selected components within these departments. We conducted this
             performance audit from July 2011 through July 2012 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 objectives. A more thorough description of our scope and
             methodology is provided in appendix I.


             Security clearances are required for access to certain national security
Background   information, which is classified at one of three levels: top secret, secret, or
             confidential. The level of classification denotes the degree of protection
             required for information and the amount of damage that unauthorized
             disclosure could reasonably cause to national security.




             9
              In 2007, DOD and ODNI formed the Joint Security and Suitability Reform Team, known
             as the Joint Reform Team, to execute joint reform efforts to achieve timeliness goals and
             improve the processes related to granting security clearances and determining suitability
             for government employment. Agencies included in this government-wide reform effort
             include the Office of Management and Budget, OPM, ODNI, and DOD’s Under Secretary
             of Defense (Intelligence).
             10
              Part 732 of Title 5 of the Code of Federal Regulations addresses national security
             positions within the federal government including the competitive service, the Senior
             Executive Service, and certain excepted service positions.




             Page 4                                                     GAO-12-800 Security Clearances
Relevant Orders and   Executive Order 10450, which was originally issued in 1953, makes the
Regulations           heads of departments or agencies responsible for establishing and
                      maintaining effective programs for ensuring that civilian employment and
                      retention is clearly consistent with the interests of the national security.
                      Agency heads are also responsible for designating positions within their
                      respective agencies as sensitive if the occupant of that position could, by
                      virtue of the nature of the position, bring about a material adverse effect
                      on national security. In addition, Executive Order 12968, issued in 1995,
                      is relevant to position designation because the order also makes the
                      heads of agencies—including executive branch agencies and the military
                      departments—responsible for establishing and maintaining an effective
                      program to ensure that access to classified information by each employee
                      is clearly consistent with the interests of national security. This order also
                      states that, subject to certain exceptions, eligibility for access to classified
                      information shall only be requested and granted on the basis of a
                      demonstrated, foreseeable need for access. Further, part 732 of Title 5 of
                      the Code of Federal Regulations provides requirements and procedures
                      for the designation of national security positions, 11 which include positions
                      that (1) involve activities of the government that are concerned with the
                      protection of the nation from foreign aggression or espionage, and
                      (2) require regular use of or access to classified national security
                      information.

                      In addition, part 732 states that most federal government positions that
                      could bring about, by virtue of the nature of the position, a material
                      adverse effect on national security must be designated as a sensitive
                      position and require a sensitivity level designation. The sensitivity level
                      designation determines the type of background investigation required,
                      with positions designated at a greater sensitivity level requiring a more
                      extensive background investigation. Part 732 establishes three sensitivity
                      levels—special-sensitive, critical-sensitive, and noncritical-sensitive—
                      which are described in figure 1. According to OPM, positions that an
                      agency designates as special-sensitive and critical-sensitive require a
                      background investigation that typically results in a top secret clearance.
                      Noncritical-sensitive positions typically require an investigation that
                      supports a secret or confidential clearance. OPM also defines non-
                      sensitive positions that do not have a national security element, but still


                      11
                        Those requirements in Part 732 apply to national security positions in the competitive
                      service, Senior Executive Service positions filled by career appointment within the
                      executive branch, and certain excepted service positions.




                      Page 5                                                     GAO-12-800 Security Clearances
                       require a designation of risk for suitability purposes. That risk level
                       determines the type of investigation required for those positions. Those
                       investigations include aspects of an individual’s character or conduct that
                       may have an effect on the integrity or efficiency of his or her service.

Position Designation   The personnel security clearance process begins when a human
Process                resources or security professional determines 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. DHS and DOD follow a general process for determining whether
                       a federal civilian position requires access to classified information, which
                       informs whether a position requires a security clearance. This process is
                       described in figure 1 below and is based on our review of the
                       corresponding guidance and testimonial evidence gathered during
                       interviews with DHS and DOD officials. In addition, a more thorough
                       description of DHS and DOD component-level policies appears in
                       appendix II.




                       Page 6                                            GAO-12-800 Security Clearances
Figure 1: DHS and DOD Security Clearance Determination Process for Federal Civilian Positions




                                        a
                                         A Single Scope Background Investigation (SSBI) is conducted so that an individual can obtain a top
                                        secret clearance (including Sensitive Compartmented Information and Q access) and includes a
                                        review of the locations where an individual has lived, attended school, and worked. In addition, an
                                        SSBI includes interviews with four references who have social knowledge of the subject, interviews
                                        with former spouses, and a financial record check.




                                        Page 7                                                           GAO-12-800 Security Clearances
                            b
                             An Access National Agency Check and Inquiries (ANACI) is used for the initial investigation for
                            federal employees at the confidential and secret access levels. It consists of employment checks,
                            education checks, residence checks, reference checks, and law enforcement agency checks, as well
                            as a National Agency Check, which includes data from military records and the Federal Bureau of
                            Investigation’s investigative index.
                            C
                             A Moderate Risk Background Investigation (MBI) includes an ANACI and provides issue-triggered
                            enhanced subject interviews with issue resolution. DHS uses the MBI for non-critical sensitive
                            positions when a position is first designated as high, moderate, or low risk.


                            The personnel security clearance process is further described in appendix
                            III.


Personnel Security          The increased demand for personnel with security clearances following
Clearance and Suitability   the events of September 11, 2001, led GAO and others to identify delays
Reforms                     and incomplete documentation in the security clearance process. In light
                            of these concerns, Congress passed the Intelligence Reform and
                            Terrorism Prevention Act of 2004 (IRTPA), 12 which set objectives and
                            established requirements for improving the clearance process, including
                            improving the timeliness of the clearance process, achieving interagency
                            reciprocity, establishing an integrated database to track investigative and
                            adjudicative information, and evaluating available technology for
                            investigations and adjudications.

                            In June 2008, Executive Order 13467 established a Suitability and
                            Security Clearance Performance Accountability Council, commonly
                            known as the Performance Accountability Council, to be the government-
                            wide governance structure responsible for driving implementation and
                            overseeing security and suitability reform efforts. 13 Further, the order
                            appointed the Deputy Director for Management at the Office of
                            Management and Budget as the chair of the council and designated the
                            Director of National Intelligence (DNI) as the Security Executive Agent
                            and the Director of OPM as the Suitability Executive Agent. Since its
                            establishment, the Performance Accountability Council has released
                            several reports 14 through the Joint Reform Team—its working-level


                            12
                                Pub. L. No. 108-458 (2004) (relevant sections codified at 50 U.S.C. § 435b).
                            13
                              Executive Order 13467 calls for investigations of suitability and security to be aligned
                            using consistent standards, to the extent practicable.
                            14
                              Joint Security and Suitability Reform Team, Security and Suitability Process Reform
                            (Washington, D.C.: April 2008 and updated December 2008); and Performance
                            Accountability Council, Security and Suitability Process Reform: Strategic Framework
                            (Washington, D.C.: February 2010).




                            Page 8                                                         GAO-12-800 Security Clearances
                                         predecessor that continues to focus on the reform effort—detailing
                                         reform-related plans, including a February 2010 strategic framework that
                                         established goals, performance measures, roles and responsibilities, and
                                         proposed metrics for determining the quality of security clearance
                                         investigations and adjudications. Those reports contained a reform plan
                                         that outlined a new seven-step process for end-to-end suitability and
                                         security clearance reform, see figure 2 below. According to ODNI officials,
                                         the first step—to “validate need,”—focuses on ensuring that the sensitivity
                                         level of positions is designated appropriately on the basis of mission
                                         needs, among other things.

Figure 2: Seven-Step Process for Suitability and Security Clearance Reform




                                         Separate from, but related to, 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. 15 Suitability requirements sometimes overlap with
                                         national security requirements. For example, the Department of Justice
                                         checks suitability to ensure that applicants for jobs with the Drug
                                         Enforcement Agency have never used illegal drugs. In addition, Health
                                         and Human Services checks the suitability of applicants for jobs working
                                         with children. Similarly, the Intelligence Community requires polygraph
                                         evaluations, among other things, to determine suitability for most
                                         intelligence positions. OPM was involved in many aspects of the
                                         suitability investigation process under Part 731 of Title 5 of the Code of



                                         15
                                          See part 731of Title 5 of the Code of Federal Regulations.




                                         Page 9                                                   GAO-12-800 Security Clearances
                         Federal Regulations, prior to the issuance of Executive Order 13467 and,
                         as the Suitability Executive Agent, the Director continues to be
                         responsible for developing and implementing uniform and consistent
                         policies and procedures to ensure the effective, efficient, and timely
                         completion of background investigations and adjudications relating to
                         determinations of suitability.

                         In contrast, the DNI was assigned a new role. Executive Order 13467
                         states that the DNI, as the Security Executive Agent, is responsible for,
                         among other things, developing uniform and consistent policies and
                         procedures to ensure the effective, efficient, and timely completion of
                         background investigations and adjudications relating to determinations of
                         eligibility for access to classified information or eligibility to hold a
                         sensitive position. In addition to these responsibilities, the Executive
                         Order also provides the DNI the authority to issue guidelines and
                         instructions to the heads of agencies to ensure appropriate uniformity,
                         centralization, efficiency, effectiveness, and timeliness in processes
                         relating to determinations by agencies of eligibility for access to classified
                         information or eligibility to hold a sensitive position. The order also states
                         that the Performance Accountability Council is responsible for ensuring
                         that the Executive Agents align their respective processes. Finally, the
                         order states that agency heads should implement any policy or procedure
                         developed by either the Performance Accountability Council or Executive
                         Agents under the order.


                         The DNI, in the capacity as Security Executive Agent responsible for
The Executive Branch     developing uniform and consistent policies related to the security
Has Not Issued           clearance process, has expressed intent to issue guidance relating to
                         national security positions. However, the DNI has not provided agencies
Clearly Defined Policy   with clearly defined policy through regulation or other guidance to help
Guidance for             ensure that executive branch agencies use appropriate and consistent
Determining When a       criteria when determining if positions require a security clearance.
                         Instead, executive branch agencies are using a position designation tool
Federal Civilian         developed by OPM. This tool is designed to determine the sensitivity level
Position Needs a         of civilian positions which, in turn, informs the type of background
                         investigation needed if a clearance is warranted. The DNI, however, did
Security Clearance       not have a role in its development even though the two Executive Agents
                         are to align their respective processes. As a result, agency officials we
                         met expressed mixed views on the effectiveness of the tool for national
                         security positions.




                         Page 10                                           GAO-12-800 Security Clearances
The DNI Has a Role to        According to Executive Order 13467, issued in June 2008, the DNI, as
Guide Agencies in            the Security Executive Agent, is responsible for developing uniform and
Designating Positions for    consistent policies and procedures for determinations of eligibility for
                             access to classified information or to hold a sensitive position. Further,
Security Clearances, But     the executive order states that agency heads shall assist the
Has Not Provided Agencies    Performance Accountability Council and Executive Agents in carrying out
with Clearly Defined         any function under the order, which includes implementing any policies or
Policy Guidance              procedures developed pursuant to the order. Although agency heads
                             retain the flexibility to make determinations regarding which positions in
                             their agency require a security clearance, the DNI is well positioned, by
                             virtue of its role as the Security Executive Agent, to provide guidance to
                             help align the process from agency to agency. The DNI, however, has not
                             provided agencies with clearly defined policy or instructions.


OPM Has Developed a Tool     To assist with position designation, the Director of OPM—the Executive
to Help Agencies             Agent for Suitability—has developed a process that includes a position
Determine the Proper         designation system and corresponding automated tool to guide agencies
                             in determining the proper sensitivity level for the majority of federal
Sensitivity Level for Most   positions. 16 This tool—namely, the Position Designation of National
Federal Positions, but the   Security and Public Trust Positions—enables a user to evaluate a
Tool Lacks Input from the    position’s national security and suitability requirements so as to determine
DNI                          a position’s sensitivity and risk levels, which in turn dictate the type of
                             background investigation that will be required for the individual who will
                             occupy that position. In most agencies outside the Intelligence
                             Community, OPM conducts the background investigations for both
                             suitability and security clearance purposes. The tool does not directly
                             determine whether a position requires a clearance, but rather helps
                             determine the sensitivity level of the position. The determination to grant a
                             clearance is based on whether a position requires access to classified
                             information or other relevant factors, and, if access is required, the
                             responsible official will designate the position to require a clearance.




                             16
                               According to OPM’s Federal Investigations Notice No. 10-06 Position Designation
                             Requirements (Aug. 11, 2010), the tool is recommended for all agencies requesting OPM
                             investigations and required for all positions in the competitive service, positions in the
                             excepted service where the incumbent can be noncompetitively converted to the
                             competitive service, and career appointments in the Senior Executive Service.




                             Page 11                                                    GAO-12-800 Security Clearances
OPM developed the position designation system and automated tool for
multiple reasons. First, OPM determined through a 2007 initiative 17 that
its existing regulations and guidance for position designation were
complex and difficult to apply, resulting in inconsistent designations. As a
result of a recommendation from the initiative, OPM created a simplified
position designation process in 2008. Additionally, OPM officials noted
that the tool is to support the goals of the security and suitability reform
efforts, which require proper designation of national security and
suitability positions.

OPM first introduced the automated tool in November 2008, and issued
an update of the tool in 2010. In August 2010, OPM issued guidance
(1) recommending all agencies that request OPM background
investigations use the tool and (2) requiring agencies to use the tool for all
positions in the competitive service, positions in the excepted service
where the incumbent can be noncompetitively converted to the
competitive service, and career appointments in the Senior Executive
Service. Both DHS and DOD components use the tool. A DHS instruction
requires personnel to designate all DHS positions by using OPM’s
position sensitivity designation guidance, which is the basis of the tool. 18
In addition, DOD issued guidance in September 2011 19 requiring its
personnel to use OPM’s tool to determine the proper position sensitivity
designation for new or vacant positions, including the establishment and
reclassification of positions. ODNI officials told us that they believe OPM’s
tool is useful for determining a position’s sensitivity level. However,
despite the DNI’s responsibility for policy related to ensuring uniformity in
the security clearance process, ODNI officials noted that the DNI did not
have input into recent revisions of OPM’s position designation tool.

This lack of coordination for revising the tool exists, in part, because the
execution of the roles and relationships between the Director of OPM and



17
  The Hadley-Springer commission was an initiative between OPM and the Assistant to
the President for National Security Affairs that focused on simplifying the federal
government investigative and adjudicative procedures to improve security requirements to
determine eligibility for access to classified information, among other things.
18
 DHS Management Instruction 121-01-007, Department of Homeland Security Personnel
Suitability and Security Program (June 2009).
19
 DOD Washington Headquarters Services, Implementation of the Position Designation
Automated Tool, (Sept. 27, 2011).




Page 12                                                  GAO-12-800 Security Clearances
the DNI as Executive Agents are still evolving, although Executive Order
13467 defines responsibilities for each Executive Agent. Accordingly, we
found that the Director of OPM and the DNI have not fully collaborated in
executing their respective roles in the process for determining position
designations. For example, OPM has had long-standing responsibility for
establishing standards with respect to suitability for most federal
government positions. Accordingly, the sections of the tool to be used for
evaluating a position’s suitability risk level are significantly more detailed
than the sections designed to aid in designating the national security
sensitivity level of the position. While most of OPM’s position designation
system, which is the basis of the tool, is devoted to suitability issues, only
two pages are devoted to national security issues, despite the reference
to national security in its title. Moreover, OPM did not seek to collaborate
with the DNI when updating the tool in 2010. Similarly, in 2010, OPM
initiated revisions to the part of the Code of Federal Regulations that
pertain to national security positions. 20 According to OPM and ODNI
officials, the revision is expected to clarify the standards for designating
whether federal positions are national security sensitive, which will help
agencies more accurately assess the sensitivity of a position. The
sensitivity level includes consideration of whether a position is eligible for
access to classified information and the level of access. Further, the
revision is currently expected to update the definition of national security
positions to include positions that could have a material impact on
national security, but might not clearly fall within the current definition in
part 732 of Title 5 of the Code of Federal Regulations. For example, such
positions include those with duties that involve the protection of borders,
ports, and critical infrastructure, as well as those with responsibilities
related to public safety, law enforcement, and the protection of
government information systems.

During our review, human capital and security officials from DHS and
DOD and the selected components affirmed that they were using the
existing tool to determine the sensitivity level required by a position.
However, in the absence of clearly defined policy from the DNI and the
lack of collaborative input into the tool’s design, officials explained that
they sometimes had difficulty in using the tool to designate the sensitivity
level of national security positions.


20
  See 75 Federal Register 77783 (Dec. 14, 2010). The comment period for that draft
revision ended on February 14, 2011. No final or interim rule has been issued, and no
executive branch agency is currently subject to the proposed revision.




Page 13                                                   GAO-12-800 Security Clearances
Audits Show Problems with    OPM regularly conducts audits of its executive branch customer agency
Position Designations        personnel security and suitability programs, which include a review of
                             position designation to assess the agencies’ alignment with OPM’s
                             position designation guidance. In the audit reports we obtained, OPM
                             found examples of inconsistency between agency position designation
                             and OPM guidance, both before and after the implementation of OPM’s
                             tool. For instance, prior to the implementation of the tool, in a 2006 audit
                             of an executive branch agency, OPM found that its sensitivity
                             designations differed from the agency’s designation in 13 of 23 positions.
                             Specifically, OPM concluded that 11 positions were underdesignated,
                             1 position was overdesignated, and 1 position was adjusted. More
                             recently, after the implementation of the tool, in an April 2012 audit of a
                             DOD agency, OPM assessed the sensitivity levels of 39 positions, and
                             OPM’s designations differed from the agency’s designations in 26 of
                             those positions. In the April 2012 report, the DOD agency agreed with
                             OPM’s recommendations related to position designation, and the audit
                             report confirmed that the agency had submitted evidence of corrective
                             action in response to the position designation recommendations. OPM
                             provided us with the results of 10 audits that it had conducted between
                             2005 and 2012, and 9 of those audit reports reflected inconsistencies
                             between OPM position designation guidance and determinations of
                             position sensitivity conducted by the agency. OPM officials noted,
                             however, that they do not have the authority to direct agencies to make
                             different designations because Executive Order 10450 provides agency
                             heads with the ultimate responsibility for designating which positions are
                             sensitive positions.

                             As of May 2012, the Naval Audit Service is currently finalizing its own
                             internal audit on its top secret requirements determination process for
                             civilian positions. While the results were not complete at the time of our
                             review, officials explained to us that they began this audit to validate their
                             top secret requirements and ensure that they have effective internal
                             controls over their designation process. 21

Agency Officials Had Mixed   DHS and DOD officials expressed varying opinions regarding the tool. For
Views of Designation Tool    instance, some of the officials we met raised concerns regarding the


                             21
                               ODNI conducted a separate position designation audit in response to the Intelligence
                             Authorization Act for Fiscal Year 2010, Pub. L. No. 111-259 (2010). In that report, ODNI
                             found that the processes the executive branch agencies followed differed somewhat
                             depending whether the position was civilian, military, or contractor.




                             Page 14                                                   GAO-12-800 Security Clearances
guidance provided through the tool and expressed that they had difficulty
implementing it. Specifically, officials from DHS’s U.S. Immigration and
Customs Enforcement stated that the use of the tool occasionally resulted
in inconsistency, such as over- or underdesignating a position, and
expressed a need for additional clear, easily interpreted guidance on
designating national security positions. DOD officials stated that they
have had difficulty implementing the tool because it focuses more on
suitability than security, and the national security aspects of DOD’s
positions are of more concern to them than the suitability aspects.
Further, an official from DOD’s Office of the Under Secretary of Defense
for Personnel and Readiness stated that the tool and DOD policy do not
always align and that the tool does not cover the requirements for some
DOD positions. For example, DOD’s implementing guidance on using the
tool states that terms differ between DOD’s personnel security policy and
the tool, and the tool might suggest different position sensitivity levels
than DOD policy requires. Also, officials from the Air Force Personnel
Security Office told us that they had challenges using the tool to classify
civilian positions, including difficulty in linking the tool with Air Force
practices for position designation. Moreover, an Air Force official stated a
concern that the definition for national security positions is broadly written
and could be considered to include all federal positions. Further,
individuals responsible for making position designation determinations
can easily reach different conclusions. For instance, officials from DHS’s
U.S. Immigration and Customs Enforcement stated that the tool is not
necessarily intuitive and users of the tool need to understand its nuances
in order to avoid overdesignating a position. Conversely, officials from the
U.S. Coast Guard stated that they found the tool to be intuitive, and that it
helps to ensure consistency in designation. Finally, officials from the
Transportation Security Administration noted that the tool is user friendly
and provides consistency for managers.

Recently, we have seen indications that the Executive Agents are working
to align their respective processes. According to OPM’s website, OPM
has conferred with the Office of Management and Budget (OMB)
concerning the possibility of reissuing pertinent sections of the Code of
Federal Regulations jointly with ODNI, with a targeted issuance before
the end of the 2012 calendar year. ODNI officials also stated their
intention to work with OPM on the revision effort. ODNI officials further
acknowledged that they are collaborating with OPM to reach agreement
on their respective roles as Executive Agents. Our prior work has found




Page 15                                           GAO-12-800 Security Clearances
                       that two or more agencies with related goals can benefit from enhancing
                       their collaboration in various areas to achieve common outcomes. 22


                       According to Executive Order 12968, the number of employees that each
The Executive Branch   agency determines is eligible for access to classified information shall be
Does Not Have a        kept to the minimum required, and, subject to certain exceptions, eligibility
                       shall be requested or granted only on the basis of a demonstrated,
Consistent Process     foreseeable need for access. Additionally, Executive Order 12968 states
for Reviewing and      that access to classified information shall be terminated when an
Validating Existing    employee no longer has a need for access, and that requesting or
                       approving eligibility for access in excess of the actual requirements is
Security Clearance     prohibited. Also, Executive Order 13467 authorizes the DNI to issue
Requirements for       guidelines or instructions to the heads of agencies regarding, among
                       other things, uniformity in determining eligibility for access to classified
Civilian Positions     information. However, the DNI has not issued policies and procedures for
                       agencies to review and revise or validate the existing clearance
                       requirements for their federal civilian positions to ensure that clearances
                       are kept to a minimum and reserved only for those positions with security
                       clearance requirements that are in accordance with the national security
                       needs of the time.

                       As previously noted, OPM published a December 2010 notice in the
                       Federal Register of a proposed revision to the Code of Federal
                       Regulations to clarify the policy for designating national security positions.
                       Again, as we previously noted, OPM’s website states that OPM has
                       conferred with OMB concerning the possibility of reissuing pertinent
                       sections of the Code of Federal Regulations jointly with ODNI. One
                       feature of the proposed revision would require all federal agencies to
                       conduct a onetime review of position descriptions and requirements over
                       a period of 2 years to ensure that all positions are properly designated
                       using the revision’s updated definition for national security positions.
                       Position descriptions not only identify the major duties and responsibilities
                       of the position, but they also play a critical role in recruitment, training,


                       22
                         GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain
                       Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
                       The areas for agencies to enhance collaboration include defining a common outcome;
                       establishing joint strategies to achieve the outcome; agreeing upon agency roles and
                       responsibilities; establishing compatible policies, procedures, and other means to operate
                       across agency boundaries; and developing mechanisms to monitor, evaluate, and report
                       the results of collaborative efforts.




                       Page 16                                                    GAO-12-800 Security Clearances
and performance management, among other things. While position
descriptions may change, so can the national security environment as
previously observed.

During our review of several DHS and DOD components, we found that
officials were aware of the need to keep the number of security
clearances to a minimum but were not always subject to a requirement to
review and validate the security clearance needs of existing positions on
a periodic basis. We found, instead, that agencies’ policies provide for a
variety of practices for reviewing the clearance needs of federal civilian
positions. According to DHS guidance, supervisors are responsible for
ensuring that (1) position designations are updated when a position
undergoes major changes (e.g., changes in missions and functions, job
responsibilities, work assignments, legislation, or classification
standards), and (2) position security designations are assigned as new
positions are created. Some components have additional requirements to
review position designation more regularly to cover positions other than
those newly created or vacant. For example,

•    U.S. Coast Guard guidance 23 states that hiring officials and
     supervisors should review position descriptions even when there is no
     vacancy and, as appropriate, either revise or review them.
•    According to officials in U.S. Immigration and Customs Enforcement,
     supervisors are supposed to review position descriptions annually
     during the performance review process to ensure that the duties and
     responsibilities on the position description are up-to-date and
     accurate. However, officials stated that U.S. Immigration and Customs
     Enforcement does not have policies or requirements in place to
     ensure any particular level of detail in that review.
DOD’s personnel security regulation and other guidance 24 provides DOD
components with criteria to consider when determining whether a position
is sensitive or requires access to classified information, and some of the
components also have developed their own guidance.



23
  U.S. Coast Guard, CG-121, Civilian Hiring Guide for Supervisors and Managers, ver. 2
(June 11, 2010).
24
  DOD 5200.2-R, Department of Defense Personnel Security Program (January 1987,
reissued incorporating changes Feb. 23, 1996) as modified by Under Secretary of
Defense Memorandum, Implementation of the Position Designation Automated Tool (May
10, 2011).




Page 17                                                 GAO-12-800 Security Clearances
•     An Air Force Instruction requires commanders to review all military
      and civilian position designations annually to ensure proper level of
      access to classified information. 25
•     The Army issued a memorandum in 2006 that required an immediate
      review of position sensitivity designations for all Army civilian positions
      by the end of the calendar year and requires subsequent reviews
      biennially. 26 That memorandum further states that if a review warrants
      a change in position sensitivity affecting an individual’s access to
      classified information, then access should be administratively adjusted
      and the periodic reinvestigation submitted accordingly. However,
      officials explained that improper position sensitivity designations
      continue to occur in the Army because they have a limited number of
      personnel in the security office relative to workload, and they only spot
      check clearance requests to ensure that they match the level of
      clearance required.
•     Officials from DOD’s Washington Headquarters Services told us that
      they have an informal practice of reviewing position descriptions and
      security designations for vacant or new positions, but they do not
      have a schedule for conducting periodic reviews of personnel security
      designations for already-filled positions.

These various policies notwithstanding, agency officials told us that they
are implemented inconsistently.

Some of the components we met were in the process of conducting a
onetime review of position designation during our review. For example,
Transportation Security Administration officials stated that they
reevaluated all of their position descriptions over the last 2 years because
the agency determined that the re-evaluation of its position designations
would improve operational efficiency by ensuring that positions were
appropriately designated by using OPM’s updated position designation
tool. Further, those officials told us that they review position descriptions
as positions become vacant or are created. Between fiscal years 2010
and 2011, while the Transportation Security Administration’s overall
workforce increased from 61,586 to 66,023, the number of investigations
for top secret clearances decreased from 1,483 to 1,127. In March 2011,
the Naval Audit Service begin an audit of its top secret requirements


25
    Air Force Instruction 31-501, Personnel Security Program Management (Jan. 27, 2005).
26
 Army Director of Counterintelligence, Human Intelligence, Disclosure and Security
Memorandum, Civilian Position Sensitivity Review (Dec. 31, 2006).




Page 18                                                   GAO-12-800 Security Clearances
determination process for civilian positions at selected activities to verify
that civilian top secret clearances are based on valid requirements and
that effective internal controls over the top secret requirements
determination process are in place. According to a Navy official, the
results of the audit were still undergoing the Navy’s internal review
process as of May 2012.

There is a cost to conducting background investigations, and a potential
for dollar savings when overdesignated positions are identified. DHS and
DOD officials acknowledged to us that overdesignating a position can
result in expenses for unnecessary investigations. When a position is
overdesignated, additional resources are unnecessarily spent conducting
the investigation and adjudication of a background investigation that
exceeds agency requirements. As stated earlier in this report, the
investigative workload for a top secret clearance is about 20-times greater
than that of a secret clearance because it must be periodically
reinvestigated twice as often as secret clearance investigations (every 5
years versus every 10 years) and requires 10 times as many investigative
staff hours. The fiscal year 2012 base price for a top secret clearance
investigation conducted by OPM is $4,005 and the periodic
reinvestigation is $2,711, while the base price of an investigation for a
secret clearance is $260. Further, the base price of a Moderate Risk
Background Investigation—most commonly used by DHS, according to
officials—is $752. However, we did not find policies in which position
designation reviews were linked to the position holders’ periodic
reinvestigations. In contrast, underdesignating a position carries security
risks, such as the potential release of classified information or the
placement of a person in a position for which they have not been properly
cleared.

Agencies employ varying practices because the DNI has not established
a requirement that executive branch agencies consistently review and
revise or validate existing position designations on a recurring basis.
Such a recurring basis could include reviewing position designations
during the periodic reinvestigation process. Without a requirement to
consistently review, revise, or validate existing security clearance position
designations, executive branch agencies—such as DHS and DOD—may
be hiring and budgeting for both initial and periodic security clearance
investigations using position descriptions and security clearance
requirements that no longer reflect national security needs. Finally, since
reviews are not being done consistently, DHS and DOD and other
executive branch agencies cannot have reasonable assurances that they
are keeping to a minimum the number of positions that require security


Page 19                                            GAO-12-800 Security Clearances
                      clearances on the basis of a demonstrated and foreseeable need for
                      access.


                      Executive Order 13467, issued in June 2008, established a Suitability and
Conclusions           Security Clearance Performance Accountability Council and appointed
                      the DNI as the Security Executive Agent and the Director of OPM as the
                      Suitability Executive Agent. However, while the order gives the Executive
                      Agents the authority to issue policy, the DNI has not provided executive
                      branch agencies with clearly defined policy and procedures for
                      determining whether federal civilian positions require a security
                      clearance. Until the DNI articulates such policy and procedures, executive
                      branch agencies, such as DHS and DOD, will not have a foundation on
                      which to build consistent and uniform policies. Further, Executive Order
                      13467 indicates that executive branch policies and procedures relating to,
                      among other things, suitability and eligibility for access to classified
                      information shall be aligned using consistent standards to the extent
                      possible. However, OPM updated its position designation tool in 2010
                      without input from the DNI. Without collaborative input from both OPM
                      and DNI in future revisions to the tool, executive branch agencies will
                      continue to risk making security clearance determinations that are
                      inconsistent or at improper levels. Finally, while Executive Order 12968
                      says that clearances should, subject to certain exceptions, be granted
                      only on the basis of a demonstrated need for access and kept to a
                      minimum, the DNI has not issued guidance that requires agencies to
                      review and revise or validate their existing federal civilian position
                      designations. Until the DNI does so, DHS and DOD, along with other
                      executive branch agencies, cannot have reasonable assurances that all
                      security clearance designations are correct, which could compromise
                      national security if positions are underdesignated, or create unnecessary
                      and costly investigative coverage if positions are overdesignated.


                      We recommend that the DNI, in coordination with the Director of OPM
Recommendations for   and other executive branch agencies as appropriate, issue clearly defined
Executive Action      policy and procedures for federal agencies to follow when determining if
                      federal civilian positions require a security clearance.

                      In addition, we recommend that, once the policy and procedures are
                      issued, the DNI and the Director of OPM collaborate in their respective
                      roles as Executive Agents to revise the position designation tool to reflect
                      that guidance.



                      Page 20                                          GAO-12-800 Security Clearances
                     Finally, we recommend that the DNI, in coordination with the Director of
                     OPM and other executive branch agencies as appropriate, issue
                     guidance to require executive branch agencies to periodically review and
                     revise or validate the designation of all federal civilian positions.


                     We provided a draft of this report to ODNI, OPM, DHS, and DOD for
Agency Comments      comment. Written comments from ODNI, OPM, and DHS are reprinted in
and Our Evaluation   their entirety in appendices IV, V, and VI respectively. Technical
                     comments were provided separately by ODNI, OPM, and DHS, and were
                     incorporated as appropriate. DOD concurred with the report without
                     written comment. We also provided a draft of the report to OMB for
                     information purposes.


ODNI Comments        In commenting on this report, ODNI stated that the report is a fair
                     assessment of existing executive branch policies for determining security
                     clearance requirements for federal civilian positions. The DNI has a lead
                     or collaborative role in our recommendations, and ODNI concurred with
                     all three. First, ODNI concurred with our recommendation that the DNI, in
                     coordination with the Director of OPM and other executive branch
                     agencies as appropriate, issue clearly defined policy and procedures for
                     federal agencies to follow when determining if federal civilian positions
                     require a security clearance. ODNI agreed that executive branch
                     agencies require simplified and uniform policy guidance to assist in
                     determining appropriate sensitivity designations, and cited steps it is
                     taking in coordination with OPM, DOD, and OMB. Specifically, ODNI
                     acknowledged its work with OMB and OPM to jointly issue revisions to
                     part 732 of Title 5 of the Code of Federal Regulations by the end of 2012.
                     Second, ODNI concurred with our recommendation that, once the policy
                     and procedures are issued, the DNI coordinate with the Director of OPM
                     to revise the position designation tool to reflect that guidance. ODNI
                     stated that it plans to work with OPM and other executive branch
                     agencies through the Security Executive Agent Advisory Committee to
                     develop a position designation tool that provides detailed descriptions of
                     the types of positions where the occupant could bring about a material
                     adverse impact to national security due to the duties and responsibilities
                     of the position. ODNI stated its belief that a tool that provides agencies
                     with detailed descriptions of this type will bring about greater uniformity
                     across the government in agency position designations. Third, ODNI
                     concurred with our recommendation that the DNI, in coordination with the
                     Director of OPM and other executive branch agencies as appropriate,
                     issue guidance to require executive branch agencies to periodically


                     Page 21                                          GAO-12-800 Security Clearances
               review and revise or validate the designation of all federal civilian
               positions. ODNI agreed with our assessment that the duties and
               responsibilities of federal positions may be subject to change, and stated
               that it plans to work with OPM and other executive branch agencies
               through the Security Executive Agent Advisory Committee to ensure that
               position designation policies and procedures include a provision for
               periodic reviews.

               While ODNI recognized that the emphasis of this report is on civilian
               positions that require access to classified information, it wished to
               emphasize that the DNI’s role as Security Executive Agent under
               Executive Order 13467 applies to all sensitive positions, and that
               positions that require access to classified information are a subset of all
               sensitive positions. ODNI stated that any guidance issued by the Security
               Executive Agent will cover all sensitive positions and associated
               investigative standards and adjudicative guidelines.


OPM Comments   OPM also commented on all three of the recommendations in this report
               in its written comments. OPM concurred with our second
               recommendation, which is addressed more directly to OPM, that its
               Director collaborate with the DNI in their respective roles as executive
               agents to revise the position designation tool to reflect updated federal
               position designation guidance. OPM stated that it committed to doing so
               in a February 2010 strategic framework document which was executed by
               officials within OMB, OPM, DOD, and ODNI. OPM also acknowledged
               that any revisions to the tool need to await final action with respect to
               proposed position designation regulations, which is consistent with our
               recommendation. In addition, OPM summarized executive orders that
               describe its authority. OPM also supported our third recommendation that
               the DNI, in coordination with the Director of OPM and other executive
               branch agencies as appropriate, issue guidance to require executive
               branch agencies to periodically review and revise or validate the
               designation of all federal civilian positions. OPM stated that it would be
               pleased to work with the DNI on guidance concerning periodic reviews of
               existing designations.

               While ODNI concurred with our first recommendation—that the DNI, in
               coordination with the Director of OPM and other executive branch
               agencies as appropriate, issue clearly defined policy and procedures for
               federal agencies to follow when determining whether federal civilian
               positions require a security clearance—OPM stated that it is not clear to
               OPM that it has a significant role in prescribing the policy and procedures


               Page 22                                          GAO-12-800 Security Clearances
for federal agencies to follow when determining if a federal civilian
position requires a security clearance. The basis for OPM’s statement is
Executive Order 12968 (as amended by Executive Order 13467), which
gives agency heads the ultimate responsibility to grant or deny security
clearances, subject to investigative standards and adjudicative guidelines
prescribed by the DNI. In this report, we acknowledge that authority to
grant or deny a security clearance resides with agency heads under
Executive Order 12968. However, as we also state in our report,
Executive Order 13467 provides the DNI the authority to issue guidelines
and instructions to the heads of agencies to ensure appropriate
uniformity, centralization, efficiency, effectiveness, and timeliness in
processes relating to determinations by agencies of eligibility for access
to classified information or eligibility to hold a sensitive position. Further,
as we state in our report, this Executive Order established a Suitability
and Security Clearance Performance Accountability Council to be the
government-wide governance structure responsible for driving
implementation and overseeing security and suitability reform efforts. This
order appointed the DNI as the Security Executive Agent and the Director
of OPM as the Suitability Executive Agent, and calls for investigations of
suitability and security to be aligned using consistent standards, to the
extent practicable. Therefore, we continue to believe that additional
guidance from the Security Executive Agent—the DNI—would help align
processes across multiple executive branch agencies, and note that
ODNI agreed with this assessment. Further, we included OPM in our
recommendation as a consulting agency in its role as the Suitability
Executive Agent and because, according to OPM, it is the investigative
service provider for much of the executive branch. Finally, we
recommended that the DNI work with other agencies as necessary in an
acknowledgement of the joint nature of reform effort and its oversight
structure through the Performance Accountability Council.

OPM’s response to this report discussed other points for consideration,
which are summarized below.

Relationship between the existing position designation tool and security
clearances: OPM stated in its comments that one of the premises upon
which this report is based is not accurate. Specifically, OPM asserted that
we repeatedly posited that agencies must perform the national security
designation in order to know whether the occupant will require a security
clearance when, in fact, whether the occupant of a particular position will
need access to classified information or eligibility for such access (i.e. a
security clearance) is one of the factors that help determine whether a
position is sensitive. Accordingly, OPM wrote that there is no basis for


Page 23                                            GAO-12-800 Security Clearances
               GAO to conclude that OPM’s position designation tool affects how
               agencies determine whether the occupant of a position requires access to
               classified information or eligibility for such access. We state in our report
               that to assist with position designation, the Director of OPM has
               developed a process that includes a position designation system and
               corresponding tool. We continue by stating that the tool does not directly
               determine whether a position requires a clearance, but rather helps
               determine the sensitivity of the position, which informs the type of
               investigation needed. We believe that these statements are consistent
               with OPM’s explanations and, therefore, do not believe that one of the
               premises upon which this report is based is inaccurate. However, we
               have reviewed and made revisions to other statements in our final report
               to ensure consistency with this point.

               Additional need for guidance to support the position designation tool:
               OPM noted that it provided us with copies of audits that OPM had
               performed on agencies that employ competitive service civilian personnel,
               where it observed inconsistencies in agency application of the tool. In its
               comments, OPM cited several reasons why this might happen. We
               believe this is consistent with our findings that OPM found examples of
               inconsistency between agency position designation and OPM guidance,
               and also that officials from executive branch departments expressed
               varying opinions to us regarding the tool. In response to other discussion
               in our report about the tool, OPM stated that its proposed revision to part
               732 of Title 5 of the Code of Federal Regulations was intended to
               establish a basis for more detailed guidance. We also note, as previously
               discussed, that OPM concurred with our recommendation to collaborate
               with the DNI to revise the tool.


DHS Comments   In its written comments, DHS noted GAO’s positive acknowledgement of
               DHS’ efforts to ensure that only those who need a security clearance are
               authorized one. Although the report does not contain any
               recommendations specifically directed to DHS, the Department stated
               that it remains committed to being an active member of the government-
               wide Suitability and Security Clearance Performance Accountability
               Council.


               We are sending copies of this report to the House Committee on
               Homeland Security. We are also sending copies to the Director of
               National Intelligence, the Director of the Office of Personnel Management,
               the Secretary of Homeland Security, the Secretary of Defense, and the


               Page 24                                           GAO-12-800 Security Clearances
Office of Management and Budget. This report will also be available at no
charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact
me 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 report. GAO staff who made major contributions to this report
are listed in appendix VII.

Sincerely yours,




Brenda S. Farrell
Director, Defense Capabilities and Management




Page 25                                         GAO-12-800 Security Clearances
Appendix I: Scope and Methodology
             Appendix I: Scope and Methodology




             This report reviewed government policies and practices for identifying
             federal civilian positions that require security clearances, and analyzed
             whether a uniform, consistent, and effective security clearance
             requirements determination process is in place. Our work focused on the
             Office of the Director of National Intelligence (ODNI), on the basis of its
             role to develop personnel security clearance policy and guidance for the
             federal government. Further, the scope of our work focused more
             specifically on the security clearance requirements of federal civilian
             positions from selected components within the Department of Homeland
             Security (DHS) and the Department of Defense (DOD), because of the
             volume of clearances that these two agencies process. Within DHS,
             selected components include the U.S. Coast Guard, U.S. Immigration and
             Customs Enforcement, and the Transportation Security Administration.
             Within DOD, selected components include the headquarters level
             elements of the Departments of the Army, the Navy, the Air Force, and
             the Washington Headquarters Services. We also included the Office of
             Personnel Management (OPM) in our review on the basis of its role
             implementing security clearance reform and as the primary investigative
             service provider of the federal government. See table 1 for a complete list
             of the agencies and departments interviewed for our review.




             Page 26                                         GAO-12-800 Security Clearances
Appendix I: Scope and Methodology




Table 1: Executive Branch Agencies and Offices Interviewed

 Executive branch agency                 Associated departments and offices
 Department of Homeland Security (DHS)   •   Office of the Chief Human Capital
                                             Officer
                                         •   Office of the Chief Security Officer
                                         •   U.S. Coast Guard
                                         •   U.S. Immigration and Customs
                                             Enforcement
                                         •   Transportation Security Administration
 Department of Defense (DOD)             •   Office of the Undersecretary of
                                             Defense for Intelligence
                                         •   Office of the Undersecretary of
                                             Defense for Personnel and Readiness
                                         •   Army’s Office of the Deputy Chief of
                                             Staff (G-2)
                                         •   Army’s Personnel Security
                                             Organization (G-3/5/7)
                                         •   Army’s Human Resources Program
                                             Development Division
                                         •   Air Force’s Manpower Agency and
                                             Central Civilian Classification Office
                                         •   Air Force’s Personnel Security Office
                                         •   Head of Security Policy (Personnel,
                                             Information, and Industrial) for the
                                             Navy
                                         •   Navy Office of Civilian Human
                                             Resources
                                         •   Washington Headquarters Services
                                         •   Defense Manpower and Data Center
 Office of Personnel Management (OPM)    •   Federal Investigative Services
 Office of the Director of National      •   Joint Reform Team representatives
 Intelligence(ODNI)
Source: GAO.



To determine the extent to which the executive branch has established
policies and procedures for agencies to use when first determining
whether federal civilian positions require a security clearance, we
interviewed key federal officials from the above mentioned federal
agencies and selected components, as well as OPM and ODNI. We




Page 27                                             GAO-12-800 Security Clearances
Appendix I: Scope and Methodology




reviewed relevant Executive Orders including 10450, 12968, and 13467, 1
Joint Reform Team 2 reports, OPM and ODNI audits, and part 732 of Title
5 of the Code of Federal Regulations 3. We also reviewed OPM’s
proposed revision to the Code of Federal Regulations, which aims to
clarify the policy for designating national security positions that was
published in the Federal Register in December 2010. We obtained and
analyzed personnel security clearance policies within DHS, DOD, and the
selected components within these departments to identify the extent to
which they have outlined processes for individuals responsible for
determining if federal civilian positions require a security clearance. In
addition, we obtained and analyzed OPM’s position designation system
and tool because agencies we visited use the tool in the position
designation process.

To determine the extent to which the executive branch has established
policies and procedures for agencies to review and revise or validate
existing federal civilian position security clearance requirements, we
interviewed knowledgeable officials from the federal agencies and
selected components in table 1. We reviewed part 732 of Title 5 of the
Code of Federal Regulations to identify the extent to which it delineates
processes and responsibilities for federal agencies to review and revise
or validate whether federal civilian positions require a security clearance.
We also analyzed DHS’s and DOD’s personnel security policies, and the
applicable policies of selected components within these departments to
identify the extent to which each department and selected component has




1
 Executive Order No. 10450, Security Requirements for Government Employment (Apr.
27, 1953 as amended), Executive Order No. 12968, Access to Classified Information
(Aug. 2, 1995 as amended), 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).
2
 In 2007, DOD and the Office of the Director of National Intelligence formed the Joint
Security Clearance Process Reform Team, known as the Joint Reform Team, to execute
joint reform efforts to achieve timeliness goals and improve the processes related to
granting security clearances and determining suitability for government employment.
Agencies included in this government-wide reform effort include the Office of Management
and Budget, OPM, ODNI, and DOD’s Office of the Undersecretary of Defense for
Intelligence.
3
 5 C.F.R. part 732 addresses national security positions within the federal government
including the competitive service, the Senior Executive Service, and certain excepted
service positions.




Page 28                                                   GAO-12-800 Security Clearances
Appendix I: Scope and Methodology




established processes for reviewing, revising, and validating existing
federal civilian position security clearance requirements.

We conducted this performance audit from July 2011 through July 2012 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 objectives.




Page 29                                          GAO-12-800 Security Clearances
Appendix II: Position Designation Guidance
                                         Appendix II: Position Designation Guidance




                                         The Department of Homeland Security (DHS), the Department of Defense
                                         (DOD), and their respective components have developed policies and
                                         procedures that relate to position designation. Both DHS and DOD
                                         policies provide criteria, in addition to those outlined in the Office of
                                         Personnel Management’s (OPM) tool, for position designating officials to
                                         use in determining the sensitivity level of the position. Table 2 below
                                         provides a descriptive comparison of DHS- and DOD-specific position
                                         designation guidance.

Table 2: Summary of Selected DHS and DOD Position Designation Guidance

Clearance level          Sensitivity level          DHS criteria                           DOD criteria
Top Secret / Sensitive   Special-Sensitive          Any position designated at a level     Positions that require access to Sensitive
Compartmented            (positions with the        higher than Critical-Sensitive by a    Compartmented Information (SCI).
Information              potential to cause         document that complements              Positions that require access to unique or
                         inestimable damage to      Executive Order 10450 and              uniquely productive intelligence sources or
                         the national security)     Executive Order 12968.                 methods vital to the United States security.
                                                                                           Positions that could cause inestimable
                                                                                           damage and/or compromise technologies,
                                                                                           plans, or procedures vital to the strategic
                                                                                           advantage of the United States. Any other
                                                                                           positions designated by appropriate
                                                                                           officials.
Top Secret               Critical-Sensitive         Positions that have the potential      Access to Top Secret information.
                         (positions with the        to cause exceptionally grave           Development or approval of plans,
                         potential to cause         damage to the national security.       policies, or programs that affect the overall
                         exceptionally grave        These positions may include            operations of DOD or DOD component.
                         damage to the national     access up to, and including, Top
                                                    Secret national security               Development or approval of war plans.
                         security)
                                                    information or materials; or other     Investigative and certain investigative
                                                    positions related to national          support duties, the issuance of personnel
                                                    security, regardless of duties, that   security clearances or the making of
                                                    require the same degree of trust.      personnel security determinations.
                                                                                           Fiduciary, public contact, or other duties.
                                                                                           Duties falling under Special Access
                                                                                           programs.
                                                                                           Category I automated data processing
                                                                                           positions responsible for, among other
                                                                                           things, the development and
                                                                                           administration of agency computer security
                                                                                           programs.
                                                                                           Any other position so designated by the
                                                                                           Head of the DOD component or designee.




                                         Page 30                                                       GAO-12-800 Security Clearances
                                         Appendix II: Position Designation Guidance




Clearance level          Sensitivity level            DHS criteria                           DOD criteria
Secret or Confidential   Noncritical-Sensitive        Positions that have the potential      Access to Secret or Confidential
                         (positions with the          to cause serious damage to the         information.
                         potential to cause serious   national security. These positions     Security police / provost marshal-type
                         damage to the national       involve either access to Secret or     duties involving the enforcement of law
                         security)                    Confidential national security         and security duties involving the protection
                                                      information materials, or duties       and safeguarding of DOD personnel and
                                                      that may adversely affect, directly    property.
                                                      or indirectly, the national security
                                                      operations of the Department.          Category II automated data processing
                                                                                             positions responsible for, among other
                                                                                             things, systems design, operation, testing,
                                                                                             maintenance, and monitoring under
                                                                                             technical review of Category I automated
                                                                                             data processing positions.
                                                                                             Duties involving education and orientation
                                                                                             of DOD personnel.
                                                                                             Duties involving the design, operation, or
                                                                                             maintenance of intrusion detection
                                                                                             systems deployed to safeguard DOD
                                                                                             personnel and property.
                                                                                             Any other position so designated by the
                                                                                             Head of the DOD component or designee.
                                         Source: DHS and DOD.

                                         Note: Data are from DHS, Management Instruction 121-01-007, The Department of Homeland
                                         Security Personnel Suitability and Security Program (June 2009), and DOD, Enclosure to the Under
                                         Secretary of Defense for Personnel and Readiness Memorandum, Implementation of the Position
                                         Designation Automated Tool (May 10, 2011).




                                         DHS’s management instruction regarding the personnel security and
Department of                            suitability program (DHS Management Instruction 121-01-007) defines
Homeland Security                        sensitivity levels and instructs the DHS components to follow OPM’s
                                         position sensitivity designation guidance when determining the proper
                                         sensitivity level for civilian positions. Further, the supervising official with
                                         sufficient knowledge of duty assignments is responsible for collaborating
                                         with Human Resources and assigning position sensitivity designations
                                         and then those designations are subject to final approval by the
                                         component’s respective Personnel Security Office.

                                         Immigration and Customs Enforcement: In addition to DHS’s
                                         management directive, Immigration and Customs Enforcement officials
                                         confirmed that they are using OPM’s position sensitivity designation
                                         guidance and position designation tool to ensure that their civilian
                                         positions have the proper sensitivity level. According to these officials, the
                                         Immigration and Customs Enforcement’s Office of Professional
                                         Responsibility and Office of Human Capital work with the program offices
                                         to establish and validate position security designations.


                                         Page 31                                                         GAO-12-800 Security Clearances
                Appendix II: Position Designation Guidance




                Transportation Security Administration: In addition to DHS’s management
                directive, the Transportation Security Administration developed informal
                guidance on the position designation process and uses OPM’s position
                designation tool to determine the sensitivity level for its positions. The
                Transportation Security Administration Personnel Security Section
                requires the manager to confirm that access to classified information is
                required to perform the duties of the position. In addition, the
                Transportation Security Administration’s Personnel Security Section does
                a final review of all position and risk designations.

                U.S. Coast Guard: According to U.S. Coast Guard officials, the U.S.
                Coast Guard follows the criteria for position designation laid out in the
                Commandant of the Coast Guard Instruction 5520.12C, Personnel
                Security and Suitability Program. In addition, those officials indicated that
                the U.S. Coast Guard uses OPM’s position designation tool for
                determining the sensitivity level for civilian positions. As part of a standard
                hiring practice, supervisors engage Human Resources with a request for
                personnel action. This initiates the prerecruitment phase of the process
                where the need of the position is validated, the position description is
                reviewed and updated, the job analysis is confirmed, and the recruitment
                strategy is executed.


                DOD’s personnel security regulation and other guidance 1 provide the
Department of   DOD components with detailed criteria to consider when determining
Defense         whether a position requires access to classified information. Although
                DOD’s policy is also under revision, the current policy incorporates OPM’s
                definitions for critical-sensitive and noncritical sensitive positions. Further,
                DOD’s regulation specifically states that personnel security clearances
                shall not normally be issued:

                •   to persons in nonsensitive positions;
                •   to persons whose regular duties do not require authorized access to
                    classified information;
                •   for ease of movement of persons within a restricted area whose duties
                    do not require access to classified information;


                1
                 DOD 5200.2-R, Department of Defense Personnel Security Program (January 1987,
                reissued incorporating changes Feb. 23, 1996) as modified by Under Secretary of
                Defense for Personnel and Readiness Memorandum, Implementation of the Position
                Designation Automated Tool (May 10, 2011).




                Page 32                                               GAO-12-800 Security Clearances
Appendix II: Position Designation Guidance




•   to persons who may only have inadvertent access to sensitive
    information or areas, such as guards, emergency service personnel,
    firefighters, doctors, nurses, police, ambulance drivers, or similar
    personnel;
•   to persons working in shipyards whose duties do not require access to
    classified information;
•   to persons who can be prevented from accessing classified
    information by being escorted by cleared personnel;
•   to food service personnel, vendors and similar commercial sales or
    service personnel whose duties do not require access to classified
    information;
•   to maintenance or cleaning personnel who may only have inadvertent
    access to classified information unless such access cannot be
    reasonably prevented;
•   to persons who perform maintenance on office equipment, computers,
    typewriters, and similar equipment who can be denied classified
    access by physical security measures;
•   to perimeter security personnel who have no access to classified
    information; and
•   to drivers, chauffeurs and food service personnel.

In addition, DOD’s Under Secretary of Defense for Personnel and
Readiness issued a memorandum requiring the use of OPM’s position
designation system and tool to determine the sensitivity level for civilian
positions. Further, some of the DOD components that we visited have
developed policies that extend beyond the DOD personnel security policy.

Army: Army officials affirmed that they use OPM’s position designation
tool to determine the sensitivity level of all civilian positions. In addition,
Army Regulation 380-67 defines sensitive positions and gives heads of
DOD components or their designees authority, subject to certain
conditions, to delegate the designation of position sensitivity within their
chain of command. Further, a 2006 Army memorandum called for
sensitivity reviews of all Army civilian positions every 2 years, at a
minimum.

Navy: According to officials, the Department of the Navy follows guidance
in the Secretary of the Navy Regulation M-5510.30 along with DOD’s
personnel security regulation, which requires designators to set the
clearance level for civilian personnel according to the risk the position
poses. According to a Navy personnel security official, Human Resources
offices and local commands have been revalidating positions according to
the needs of the command in response to a 2011 memorandum from the



Page 33                                              GAO-12-800 Security Clearances
Appendix II: Position Designation Guidance




Assistant Secretary of the Navy for Manpower and Reserve Affairs.
According to Navy officials, Human Resources offices used the position
designation tool provided by OPM to determine the sensitivity level for all
civilian positions.

Air Force: The Air Force uses Air Force Instruction 31-501 coupled with
the DOD 5200.2-R to implement its personnel security program.
According to the instruction, commanders with position designation
authority determine the security sensitivity of civilian positions. Each
position is coded with the appropriate security access requirement and
identified in the unit manning document and the Defense Civilian
Personnel Data System. If the security access requirement code requires
a change, the unit commander submits an authorization change request
to the servicing security activity. The commander also conducts an annual
review of positions to determine the accuracy of position coding and
adjust coding if necessary. Air Force officials confirmed that they are
using OPM’s Position Designation System and Tool to determine the
proper sensitivity level for all civilian positions. Also, according to Air
Force officials, in situations where a commander wants to upgrade a
particular position, it must be reviewed and approved by a 3-star general.

Washington Headquarters Services: Washington Headquarters Services
oversees position designation for certain DOD headquarters activities and
defense agencies. According to Washington Headquarters Services
officials, these agencies and activities follow DOD’s personnel security
regulation for position designation and use OPM’s position designation
system and tool in accordance with DOD policy. 2




2
 See Washington Headquarters Services memorandum entitled Implementation of the
Position Designation Automated Tool (Sept. 27, 2011).




Page 34                                              GAO-12-800 Security Clearances
Appendix III: Personnel Security Clearance
              Appendix III: Personnel Security Clearance
              Process



Process

              Since 1997, federal agencies have followed a common set of personnel
              security investigative standards and adjudicative guidelines for
              determining whether federal workers and others 1 are eligible to receive
              security clearances. 2 Once an applicant is selected for a position that
              requires a security clearance, government agencies rely on a multiphased
              personnel security clearance process that includes the application
              submission phase, investigation phase, and adjudication phase, among
              others. Different departments and agencies may have slightly different
              security clearance processes—the steps outlined below are intended to
              be illustrative of a typical process.

              •   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 the Office of Personnel Management’s
                  (OPM) 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 the investigation service
                  provider.
              •   The investigation phase. Federal investigative standards and OPM’s
                  internal guidance are typically used to conduct and document the
                  investigation of the applicant. The scope of information gathered in an
                  investigation depends on the level of clearance needed and whether
                  the investigation is for an initial clearance or a reinvestigation for a
                  clearance renewal. 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. After the investigation is complete, the resulting
                  investigative report is provided to the agency.



              1
               Others include military servicemembers and private industry personnel; however, the
              scope of this report is federal civilian workers.
              2
               Memorandum from Samuel Berger, Assistant to the President for National Security
              Affairs, to George J. Tenet and John P. White, Co-Chairmen, Security Policy Board,
              Implementation of Executive Order 12968 (Mar. 24, 1997). This memorandum approves
              the adjudication guidelines, temporary eligibility standards, and investigative standards
              required by Executive Order 12968, Access to Classified Information (Aug. 2, 1995), as
              amended. The standards were later published in 32 C.F.R. Part 147. Further, the
              standards were updated in 2005; however, those updates are not currently reflected at 32
              C.F.R. Part 147.




              Page 35                                                   GAO-12-800 Security Clearances
Appendix III: Personnel Security Clearance
Process




•   The adjudication phase. Adjudicators from an agency 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.

In addition, once the background investigation and adjudication for a
security clearance are complete, the requesting agency determines
whether the individual is eligible for access to classified information.
However, often the security clearance—either at the secret or top secret
level—does not become effective until an individual needs to work with
classified information. At that point, the individual would sign a
nondisclosure agreement and receive a briefing in order for the clearance
to become effective. DOD commonly employs this practice and, in some
cases, the individual ultimately never requires access to classified
information. Therefore, not all security clearance investigations result in
an active security clearance.

Finally, once an individual is 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 clearanceholders are reinvestigated
every 5 years, and secret clearanceholders are reinvestigated every 10
years.




Page 36                                           GAO-12-800 Security Clearances
Appendix IV: Comments from the Office of
              Appendix IV: Comments from the Office of the
              Director of National Intelligence



the Director of National Intelligence




              Page 37                                        GAO-12-800 Security Clearances
Appendix IV: Comments from the Office of the
Director of National Intelligence




Page 38                                        GAO-12-800 Security Clearances
Appendix IV: Comments from the Office of the
Director of National Intelligence




Page 39                                        GAO-12-800 Security Clearances
Appendix V: Comments from the Office of
              Appendix V: Comments from the Office of
              Personnel Management



Personnel Management




              Page 40                                   GAO-12-800 Security Clearances
Appendix V: Comments from the Office of
Personnel Management




Page 41                                   GAO-12-800 Security Clearances
Appendix V: Comments from the Office of
Personnel Management




Page 42                                   GAO-12-800 Security Clearances
Appendix V: Comments from the Office of
Personnel Management




Page 43                                   GAO-12-800 Security Clearances
Appendix V: Comments from the Office of
Personnel Management




Page 44                                   GAO-12-800 Security Clearances
Appendix VI: Comments from the
             Appendix VI: Comments from the Department
             of Homeland Security



Department of Homeland Security




             Page 45                                     GAO-12-800 Security Clearances
Appendix VII: GAO Contact and Staff
                  Appendix VII: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov
GAO Contact
                  In addition to the contact named above, David Moser (Assistant Director),
Staff             Sara Cradic, Cynthia Grant, Nicole Harris, Jeffrey Heit, Kimberly Mayo,
Acknowledgments   Richard Powelson, Jason Wildhagen, Michael Willems, and Elizabeth
                  Wood made key contributions to this report.




                  Page 46                                        GAO-12-800 Security Clearances
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             Enhance Momentum Gained from Reform Effort. GAO-12-815T.
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             Improve Transparency of Its Pricing and Seek Cost Savings.
             GAO-12-197. Washington, D.C.: February 28, 2012.

             High-Risk Series: An Update. GAO-11-278. Washington, D.C.: February
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             Personnel Security Clearances: Overall Progress Has Been Made to
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             Page 47                                      GAO-12-800 Security Clearances
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to Further Improve the Clearance Process. GAO-09-400. Washington,
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High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January
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DOD Personnel Clearances: Preliminary Observations about Timeliness
and Quality. GAO-09-261R. Washington, D.C.: December 19, 2008.

Personnel Security Clearances: Preliminary Observations on Joint
Reform Efforts to Improve the Governmentwide Clearance Eligibility
Process. GAO-08-1050T. Washington, D.C.: July 30, 2008.

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Clearance Reform. GAO-08-965R. Washington, D.C.: July 14, 2008.

Personnel Clearances: Key Factors for Reforming the Security Clearance
Process. GAO-08-776T. Washington, D.C.: May 22, 2008.

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GAO-08-551T. Washington, D.C.: April 9, 2008.

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Quality and Timeliness of Clearances. GAO-08-580R. Washington D.C.:
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to Improve Clearance Processes for Industry Personnel. GAO-08-470T.
Washington, D.C.: February 12, 2008.

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Security Clearance Processes. GAO-08-352T. Washington, D.C.:
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More Informed Congressional Oversight. GAO-08-350. Washington, D.C.:
February 13, 2008.

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Page 48                                       GAO-12-800 Security Clearances
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(351644)
           Page 49                                      GAO-12-800 Security Clearances
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