oversight

Personnel Security Clearances: Continuing Leadership and Attention Can Enhance Momentum Gained from Reform Effort

Published by the Government Accountability Office on 2012-06-21.

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

                            United States Government Accountability Office

GAO                         Testimony
                            Before the Subcommittee on Oversight of Government
                            Management, the Federal Workforce, and the District of
                            Columbia, Committee on Homeland Security and
                            Governmental Affairs, U. S. Senate

                            PERSONNEL SECURITY
For Release on Delivery
Expected at 2:30 p.m. EDT
Thursday, June 21, 2012

                            CLEARANCES
                            Continuing Leadership and
                            Attention Can Enhance
                            Momentum Gained from
                            Reform Effort
                            Statement of Gene L. Dodaro
                            Comptroller General of the United States




GAO-12-815T
                                                June 21, 2012

                                                PERSONNEL SECURITY CLEARANCES
                                                Continuing Leadership and Attention Can Enhance
                                                Momentum Gained from Reform Effort
Highlights of GAO-12-815T, a testimony
before the Subcommittee on Oversight of
Government Management, the Federal
Workforce, and the District of Columbia,
Committee on Homeland Security and
Governmental Affairs, U.S. Senate

Why GAO Did This Study                          What GAO Found
As of October 2010, the Office of the           Since GAO first identified the Department of Defense’s (DOD) Personnel
Director of National Intelligence               Security Clearance Program as a high-risk area, DOD, in conjunction with
reported that 3.9 million federal               Congress and executive agency leadership, took actions that resulted in
employees (military and civilians) and          significant progress toward improving the processing of security clearances.
contractors hold security clearances.           Congress held more than 14 oversight hearings to help oversee key legislation,
DOD comprises the vast majority of              such as the Intelligence Reform and Terrorism Prevention Act of 2004, which
government security clearances.                 helped focus attention and sustain momentum of the governmentwide reform
Longstanding backlogs and delays in             effort. In addition, the committed and collaborative efforts of DOD, the Office of
the security clearance process led              the Director of National Intelligence (ODNI), Office of Management and Budget
GAO to place the DOD’s Personnel                (OMB), and Office of Personnel Management (OPM) as leaders of the Suitability
Security Clearance Program on its               and Security Clearance Performance Accountability Council (Performance
high-risk list in 2005. Delays in issuing       Accountability Council) demonstrated commitment to and created a vision for the
clearances can result in millions of            reform effort, which led to significant improvements in the timeliness of
dollars of additional cost to the federal
                                                processing security clearances. As a result, in 2011, GAO removed DOD’s
government and could pose a national
                                                Personnel Security Clearance Program from its high-risk list because of the
security risk. DOD and others have
taken steps to address these issues
                                                agency’s progress in improving timeliness, development of tools and metrics to
and additional concerns with clearance          assess quality, and commitment to sustaining progress. Specifically, GAO found
documentation used to determine                 that DOD met the 60-day statutory timeliness objective for processing initial
eligibility for a clearance. As a result, in    clearances in fiscal year 2010 by processing 90 percent of its initial clearances in
2011, GAO removed the program from              an average of 49 days. In addition, DOD developed two quality tools to evaluate
its high-risk list.                             completeness of investigation documentation and agencies' adjudication process
                                                regarding the basis for granting security clearances. Moreover, DOD, ODNI,
This testimony addresses (1) the key            OMB, and OPM developed and are in the process of implementing 15 metrics
actions that led GAO to remove DOD’s            that assess the timeliness and quality of investigations, adjudications, reciprocity
security clearance program from its
                                                and automation of security clearances.
high-risk list and (2) the additional
actions that can enhance the security           Even with the significant progress in recent years, sustained leadership attention
clearance reform efforts. This                  to the following additional actions, on which GAO has previously reported, can
statement is based on prior GAO                 enhance the security clearance reform efforts of executive branch agencies and
reports and testimonies on DOD’s                the Performance Accountability Council:
personnel security clearance program
and governmentwide suitability and              •   Continue to implement, monitor, and update outcome-focused performance
security clearance reform efforts.                  measures. The development of tools and metrics to monitor and track quality
                                                    are positive steps, but full implementation of these tools and measures will
                                                    enable the executive branch to demonstrate progress in quality
                                                    improvements and contribute to greater visibility over the clearance process.
                                                •   Seek opportunities to enhance efficiencies and manage costs related to the
                                                    reform effort. Given the current fiscal constraints, identifying long-term
                                                    funding requirements for the security clearance process is critical for the
                                                    executive branch to sustain the reform effort. Further, the reform efforts are a
                                                    venue to facilitate the identification of efficiencies in areas including
                                                    information technology and investigation and adjudication case management
                                                    processes.
                                                •   Create a sound requirements process for determining which positions require
                                                    clearances and level of clearances. A sound requirements determination
                                                    process may help ensure that workload and costs are not higher than
View GAO-12-815T. For more information,             necessary by ensuring that clearances are only requested for positions when
contact Brenda S. Farrell at (202)512-3604 or
farrellb@gao.gov.                                   needed and that the appropriate clearance level is requested.

                                                                                         United States Government Accountability Office
Chairman Akaka, Ranking Member Johnson, and Members of the
Subcommittee:

Thank you for the opportunity to discuss the removal of the Department of
Defense’s (DOD) personnel security clearance program from our high-risk
list. 1 As you know, we maintain a program to focus attention on
government operations that we identify as high risk due to their greater
vulnerabilities to fraud, waste, abuse, and mismanagement or the need
for transformation to address economy, efficiency, or effectiveness
challenges. In the past two decades, the attention of Congress, the
agencies, and others to high-risk areas has brought results. Over
one-third of the areas previously designated as high-risk have been
removed from the list because significant progress was made to address
the problems. When legislative, administrative, and agency actions,
including those in response to our recommendations, result in significant
progress toward resolving a high-risk problem, we remove the high risk
designation. In 2011, DOD’s personnel security clearance program
became the first designated defense area to be removed from our high-
risk list. Seven DOD high-risk areas remain on the list. My testimony
today will focus on (1) the key actions that led us to remove DOD’s
personnel security clearance program from our high-risk list, and (2)
additional actions that can enhance the governmentwide personnel
security clearance reform efforts.

Personnel security clearances allow government and industry 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 2010 unauthorized leaks of about 500,000
classified documents posted to the Internet related to the wars in
Afghanistan and Iraq are examples of the inherent risks involved when
granting an individual a security clearance. As you know, there continues
to be a high volume of clearances processed. For example, prior to
September 11, 2001, we reported that DOD processed about 200,000
clearances annually. For fiscal year 2008, we reported that DOD
approved personnel security clearances for approximately 630,000
military, civilian, and industry personnel. In 2010, the Director of National
Intelligence reported that there were approximately 3.9 million federal
government and contractor employees who held a security clearance.



1
    GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2007).




Page 1                                                                    GAO-12-815T
DOD accounts for the vast majority of all initial personnel security
clearances, making it a formidable challenge to those responsible for
deciding who should be granted a clearance.

Multiple executive-branch agencies are responsible for different phases in
the federal government’s personnel security clearance process. With
respect to DOD’s personnel security clearance program, DOD is
responsible for determining which military, DOD civilian, and private-
industry personnel working on DOD contracts require access to classified
information and must apply for a security clearance and undergo an
investigation. The Office of Personnel Management (OPM), in turn,
conducts these investigations for DOD. OPM investigators—often
contractors—use federal investigative standards and OPM internal
guidance as criteria for collecting background information on applicants.
Federal guidelines require that DOD adjudicators use the information
contained in the resulting investigative reports to determine whether an
applicant is eligible for a personnel security clearance.

We first placed DOD’s personnel security clearance program on our high-
risk list in 2005. Some of the problems included (1) delays in completing
clearances; (2) incomplete investigative reports from OPM, the agency
that reportedly supplies about 90 percent of all federal clearance
investigations, including those for DOD; and (3) the granting of some
clearances by DOD adjudicators even though required data were missing
from the investigative reports used to make such determinations. We also
reported that delays in issuing clearances can result in millions of dollars
of additional cost to the federal government. Furthermore, during this
period the executive branch initiated actions to reform the
governmentwide security clearance process.

My testimony is based on our issued reports and testimonies on DOD’s
personnel security clearance program and governmentwide suitability and
security clearance reform efforts. 2 Our reports and testimonies were
conducted in accordance with generally accepted government auditing
standards.




2
 See related GAO products at the end of this statement. More information on our scope
and methodology is included in each issued report.




Page 2                                                                     GAO-12-815T
                       Since we identified DOD’s Personnel Security Clearance program as a
Leadership             high-risk area, DOD, in conjunction with Congress and other executive
Commitment,            agency leadership, took actions that resulted in significant progress
                       toward resolving problems we identified with the security clearance
Improved Timeliness,   program. In 2011, we removed DOD’s personnel security clearance
and Development of     program from our high-risk list because of the agency’s progress in
Metrics Were Key to    improving timeliness and the development of tools and metrics to assess
                       quality, as well as DOD’s commitment to sustaining progress. Importantly,
Removal of DOD’s       congressional oversight and the committed leadership of the Suitability
Security Clearance     and Security Clearance Performance Accountability Council
                       (Performance Accountability Council) 3 –which has been responsible for
Program from GAO’s     overseeing security clearance reform efforts since 2008—greatly
High-Risk List         contributed to the progress of DOD and the governmentwide security
                       clearance reform. 4


Top Leadership         Leadership in Congress and the executive branch demonstrated
Demonstrated           commitment to reforming the security clearance process to address
Commitment and         longstanding problems associated with the personnel security clearance
                       program. As we have previously noted, top leadership must be committed
Collaboration in       to organizational transformation. 5 Specifically, leadership must set the
Reforming Security     direction, pace, and tone and provide a clear, consistent rationale that
Clearance Process      brings everyone together behind a single mission. Figure 1 illustrates key
                       events related to the Suitability and Personnel Security Clearance Reform
                       Effort.




                       3
                         The Performance Accountability Council is comprised of the Director of National
                       Intelligence as the Security Executive Agent, the Director of OPM as the Suitability
                       Executive Agent, and the Deputy Director for Management, OMB, as the chair with the
                       authority to designate officials from additional agencies to serve as members. The current
                       council includes representatives from the Departments of Defense, Energy, Health and
                       Human Services, Homeland Security, State, Treasury, and Veterans Affairs, and the
                       Federal Bureau of Investigation.
                       4
                         Determinations of suitability for government employment in positions in the competitive
                       service and for career appointment in the Senior Executive Service include consideration
                       of aspects of an individual’s character or conduct that may have an effect on the integrity
                       or efficiency of their service.
                       5
                         GAO, 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).




                       Page 3                                                                         GAO-12-815T
Figure 1: Key Events Related to the Suitability and Personnel Security Clearance Reform Effort




Congressional Leadership                 Congressional legislation and oversight has helped focus attention and
                                         sustain momentum to improve the processing of security clearances not
                                         only for DOD but governmentwide. The Intelligence Reform and
                                         Terrorism Prevention Act of 2004 (IRTPA) 6 established, among other
                                         things, milestones for reducing the time to complete initial clearances. We
                                         previously identified best practices for agencies to successfully transform



                                         6
                                          Pub. L. No. 108-458, 118 Stat. 3638 (2004).




                                         Page 4                                                          GAO-12-815T
their cultures including among other things, setting implementation goals
and a timeline to build momentum and show progress from day one. 7
IRTPA established an interim objective to be met by December 2006
under which DOD and other agencies that adjudicate security clearances
were to make a decision on at least 80 percent of initial clearance
applications within 120 days, on average. Further, IRTPA called for the
executive branch to implement a plan by December 17, 2009, under
which, to the extent practical, at least 90 percent of decisions are made
on applications for an initial personnel security clearance within 60 days,
on average. Additionally, IRTPA required the executive branch to begin
providing annual reports to Congress in 2006 on the progress made the
preceding year toward meeting IRTPA’s objectives for security
clearances, including the length of time agencies took to complete the
investigations and adjudications—the decision as to whether an individual
should be granted eligibility for a clearance.

Congressional oversight through hearings held by this Subcommittee
helped highlight the need for security clearance reform. From 2005 to
2010, congressional committees held more than 14 hearings on security
clearance reform, with 7 held by this Subcommittee. 8 This
subcommittee’s oversight helped set the direction for the agencies,
including GAO, to work collaboratively on developing metrics in order to
address our concerns about the completeness and quality of
investigations and adjudications. Many federal program efforts, including
those related to personnel security, generally require the effective
collaboration of more than one agency. For example, on March 17, 2010,
the leaders of the reform effort—the Office of Management and Budget
(OMB), OPM, Office of the Director of National Intelligence (ODNI), and
DOD—along with GAO, met with this Subcommittee’s Chairman and
then-Ranking Member to discuss the status of security clearance reform
efforts and consult on metrics that could be used to measure progress of


7
  GAO, Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned for
the Department of Homeland Security and Other Federal Agencies, GAO-03-293SP
(Washington, D.C.: Nov. 14, 2002), and Results-Oriented Cultures: Implementation Steps
to Assist Mergers and Organizational Transformations, GAO-03-669 (Washington, D.C.:
July 2, 2003).
8
  GAO has testified on security clearance reform before this committee as well as the (1)
Subcommittee on Intelligence Community Management, House Permanent Select
Committee on Intelligence, (2) the Subcommittee on Government Management,
Organization, and Procurement, House Committee on Oversight and Government Reform,
and (3) Subcommittee on Readiness, House Committee on Armed Services.




Page 5                                                                      GAO-12-815T
                              security clearance reform efforts. After that meeting, OMB, ODNI, DOD,
                              OPM, and GAO provided a memorandum on May 31, 2010 to Chairman
                              Akaka containing a matrix with 15 metrics for assessing the timeliness
                              and quality of investigations, adjudications, reciprocity (an agency’s
                              acceptance of a background investigation or clearance determination
                              completed by any authorized investigative or adjudicative agency), and
                              automation. 9 The development of these metrics played a key role in
                              GAO’s decision to remove DOD’s Personnel Security Clearance program
                              from the high-risk list.

                              Furthermore, we have noted for many years the central role that the
                              Government Performance and Results Act (GPRA) could play in
                              identifying and fostering improved coordination across related federal
                              program efforts. The GPRA Modernization Act of 2010 (GPRAMA) 10 calls
                              for a more coordinated and crosscutting approach to achieve meaningful
                              results. 11 GPRAMA provides an opportunity for agencies to collect and
                              report more timely and useful performance information on crosscutting
                              programs. This performance information can play an important role in
                              congressional decision making. In fact, Mr. Chairman, we conducted work
                              for you focusing on how Congress can use such information to address
                              challenges facing the government. 12 DOD’s personnel security clearance
                              program was one of three case studies we used to illustrate how
                              Congress has used agency performance information in its decision
                              making.

Executive Branch Leadership   In addition to congressional leadership, multiple administrations, DOD,
                              and key executive agencies demonstrated a commitment and vision to
                              reform the security clearance process. Specifically, after we initially


                              9
                               We participated in legislative and executive branch discussions on development of these
                              metrics. However, given the need for GAO to remain independent in carrying out its
                              auditing responsibilities of the executive branch, decisions related to performance
                              measures and their effective implementation are fundamentally an executive branch
                              management responsibility.
                              10
                                Pub. L. No. 111-352, 124 Stat. 3886 (2011). GPRAMA amended the Government
                              Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285 (1993).
                              11
                                 GAO, Managing for Results: GPRA Modernization Act Implementation Provides
                              Important Opportunities to Address Government Challenges, GAO-11-617T (Washington,
                              D.C.: May 10, 2011).
                              12
                                GAO, Managing for Results: Opportunities for Congress to Address Government
                              Performance Issues, GAO-12-215R (Washington, D.C.: Dec. 9, 2011).




                              Page 6                                                                     GAO-12-815T
placed the program on our high-risk list, top executive branch leadership
put in place an effort to reform the security clearance process. For
example, in 2007, DOD and ODNI formed the Joint Security Clearance
Process Reform Team, known as the Joint Reform Team, to improve the
security clearance process governmentwide. 13 Specifically, they tasked
the Joint Reform Team to execute joint reform efforts so that they achieve
IRTPA timeliness goals and improve the processes related to granting
security clearances. 14 In 2008, the President in a memorandum called for
a reform of the security clearance program and subsequently issued an
executive order establishing the Performance Accountability Council. 15
Under the executive order, this council is accountable to the President for
leading the implementation of reform, including aligning security and
suitability processes, holding agencies accountable for implementation,
and establishing goals and metrics for progress.

DOD worked with the Joint Reform Team and the Performance
Accountability Council to develop a corrective action plan to improve
timeliness and demonstrate progress toward reforming the security
clearance process. For example,

•    DOD’s leadership, in conjunction with the Joint Reform Team,
     developed a plan for reform that continuously evolved to incorporate



13
   In June 2007, the Director of National Intelligence and Under Secretary of Defense for
Intelligence through a memorandum of agreement established The Joint Security Process
Reform Team.
14
   The Joint Reform Team continues to work on the reform effort under the Performance
Accountability Council by providing progress reports, recommending research priorities,
and overseeing the development and implementation of an information technology
strategy, among other things. Since its formation, the Joint Reform Team under the
Performance Accountability Council: (1) Submitted an initial reform plan to the President
on April 30, 2008. The plan proposed a new process for determining clearance eligibility
that departs from the current system in a number of ways, including the use of a more
sophisticated electronic application, a more flexible investigation process, and the
establishment of ongoing evaluation procedures between formal clearance investigations.
The report was updated in December 2008 to include an outline of reform progress and
further plans. (2) Issued an Enterprise Information Technology Strategy to support the
reformed security and suitability process in March 2009. According to the report, the Joint
Reform Team is pursuing an approach that leverages existing systems and capabilities,
where applicable, and developing new tools where necessary.
15
   Exec. Order No. 13467, Reforming Processes Related to Suitability for Government
Employment, Fitness for Contractor Employees, and Eligibility for Access to Classified
National Security Information (June 30, 2008).




Page 7                                                                         GAO-12-815T
     new goals and address identified issues. To communicate these
     plans, the Joint Reform Team issued an initial reform plan in April
     2008 that presented a new seven-step design intended to streamline
     the security clearance process, including the use of a more
     sophisticated electronic application, a more flexible investigation
     process, and the establishment of ongoing evaluation procedures
     between formal clearance investigations. The report was updated in
     December 2008 to include an outline of reform progress and further
     plans, and in March 2009 the Joint Reform Team issued its Enterprise
     Information Technology Strategy for the security clearance and
     suitability reform program. Then, in line with GAO recommendations,
     DOD worked with the Performance Accountability Council to issue a
     strategic framework that the council included in its 2010 report to the
     President. The strategic framework identified key governmentwide
     reform goals and identified the root causes for timeliness delays and
     delays to agencies honoring reciprocity. It also set forth a
     governmentwide mission, performance measures, a communications
     strategy, roles and responsibilities, and metrics to measure the quality
     of security clearance investigations and adjudications. DOD continues
     to work with the Performance Accountability Council to sustain
     clearance reform efforts and enhance transparency and accountability
     through annual reporting to Congress. 16

•    DOD issued guidance on adjudication standards. In May 2009, we
     found that although DOD asserted that adjudicators follow a risk-
     management approach for granting security clearances, DOD had not
     issued formal guidance clarifying if and under what circumstances
     adjudicators can adjudicate incomplete investigative reports—such as
     missing information relevant to residences, employment, or education.
     As a result, we recommended that DOD issue guidance that clarifies
     when adjudicators may use incomplete investigative reports as the
     basis for granting clearances. Subsequently, on November 8, 2009,
     the Under Secretary of Defense for Intelligence issued guidance on
     adjudication standards that outline the minimum documentation
     requirements adjudicators must adhere to when documenting
     personnel security clearance determinations for cases with potentially
     damaging information. On March 10, 2010, the Under Secretary of


16
   Annual reports were required under IRTPA through 2011. Section 367 of the
Intelligence Authorization Act for Fiscal Year 2010, Pub. L. No. 111-259 (2010),
established new annual reporting requirements in section 506H of the National Security
Act of 1947 (50 U.S.C. § 415a-10).




Page 8                                                                      GAO-12-815T
                                Defense for Intelligence issued additional guidance that clarifies when
                                adjudicators may use incomplete investigative reports as the basis for
                                granting clearances. This guidance provides standards that can be
                                used for the sufficient explanation of incomplete investigative reports.
                                Further, according to DOD officials, in 2010, DOD created a
                                Performance Accountability Directorate within the Directorate of
                                Security to provide oversight and accountability for the DOD Central
                                Adjudication Facilities that process DOD adjudicative decisions.

DOD Developed             One of DOD’s key actions that led to the removal of its personnel security
Assessment Tools and      clearance program from our high-risk list was that DOD was able to
Performance Metrics and   demonstrate its progress in having implemented corrective measures.
                          Longstanding backlogs and delays in the clearance process led to our
Improved Timeliness to    initial designation of this area as high risk. For example, in 2004, we
Demonstrate Progress      testified that from fiscal year 2001 through fiscal year 2003, the average
                          time for DOD to determine clearance eligibility for industry personnel
                          increased by 56 days to over 1 year. 17 In 2005, we reported that DOD
                          could not estimate the full size of its backlog, but we identified over
                          350,000 cases exceeding established timeframes for determining
                          eligibility. 18 Moreover, in 2007 and 2009, we reported that clearances
                          continued to take longer than the timeliness goals prescribed in IRTPA. 19
                          In 2011, we reported that DOD processed 90 percent of initial clearances
                          in an average of 49 days for federal civilians, military, and industry


                          17
                             GAO, DOD Personnel Clearances: Preliminary Observations Related to Backlogs and
                          Delays in Determining Security Clearance Eligibility for Industry Personnel, GAO-04-202T
                          (Washington, D.C.: May 6, 2004).
                          18
                               High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January 2005.
                          19
                             IRTPA required agencies to make a determination of eligibility for a clearance on at
                          least 80 percent of all applications within an average of 120 days after the date of receipt
                          of the application, with a maximum of 90 days allotted for the investigation and a
                          maximum of 30 days allotted for the adjudication by no later than December 17, 2006. We
                          found that clearances in 2007 for DOD industry personnel took an average of 325 days to
                          complete. We also found that the application-submission phase averaged 111 days for
                          industry personnel seeking initial top secret clearances, but the government goal is 14
                          days. In the investigation phase, we found that it took an average of 286 days for initial
                          clearances—compared with the goal of 180 days—and 419 days for clearances updates
                          for the 2,259 industry personnel who were granted clearance eligibility in January and
                          February 2006. GAO, High-Risk Series: An Update, GAO-07-310 (Washington, D.C.:
                          January 2007). In our 2009 high-risk update, GAO-09-271, we noted that DOD made
                          significant progress toward meeting statutory timeliness goals for initial clearances. In
                          December 2008, we reported that a sample of initial DOD clearances completed in fiscal
                          year 2008 took an average of 87 days.




                          Page 9                                                                         GAO-12-815T
personnel and met the 60-day statutory timeliness objective for
processing all initial clearances in fiscal year 2010. Also we found that
DOD completed 90 percent of initial clearances for industry personnel in
an average of 63 days for all the data we reviewed in fiscal year 2010, 20
demonstrating an improvement from what we found in 2004, when the
average processing time for industry personnel was over a year.

Our high-risk designation was based not only on problems with timeliness
but also incomplete documentation of investigations and adjudications.
We reported on missing documentation in investigative reports prepared
by OPM that DOD adjudicators had used to make clearance eligibility
decisions. In 2009, we estimated that 87 percent of about 3,500 OPM
investigative reports provided to DOD in July 2008 were missing required
documentation, which in most cases pertained to residences,
employment, and education. DOD adjudicators granted clearance
eligibility without requesting missing investigative information or fully
documenting unresolved issues in 22 percent of DOD’s adjudicative files.
These findings led us to recommend that OPM and DOD, among other
things, develop and report metrics on completeness and other measures
of quality for investigations and adjudications that address the
effectiveness of the new procedures. DOD agreed and implemented our
recommendations regarding adjudication. OPM neither concurred nor
nonconcurred with our recommendation; however, as noted earlier, OPM
has taken steps to develop metrics.

Subsequently, DOD developed two quality tools to evaluate
completeness of documentation used to determine clearance eligibility.
First, the Rapid Assessment of Incomplete Security Evaluations (RAISE)
tracks the quality of investigations conducted by OPM. Results of RAISE
will be reported to the Director of National Intelligence, which, as the
Security Executive Agent of the Performance Accountability Council, will
arbitrate any potential disagreements between OPM and DOD and clarify
policy questions. DOD deployed RAISE to four Central Adjudication
Facilities from July to October 2010 and planned to complete deployment
to the remaining Central Adjudication Facilities by calendar year 2011.
According to DOD officials, as of June 2012 this tool has been deployed
to all of DOD’s non-intelligence agencies adjudication facilities. Although
the Joint Reform Team is considering using it in the future, it is not being



20
     GAO-11-278.




Page 10                                                           GAO-12-815T
used by other executive agencies. Second, in 2008 DOD developed the
Review of Adjudication Documentation Accuracy and Rationales
(RADAR), which tracks the quality of clearance adjudications. In 2009,
the Under Secretary of Defense for Intelligence directed DOD Central
Adjudication Facilities to provide adjudication case records to the Defense
Personnel Research Center for analysis. According to DOD officials, the
department plans to use results of the RADAR assessments to monitor
Central Adjudication Facilities’ compliance with documentation policies,
communicate performance to the Central Adjudication Facilities, identify
potential weaknesses and training needs, increase compliance, and
establish trend data. DOD has completed a pilot program for the use of
RADAR and began its implementation for the Army, Defense Industrial
Security Clearance Office, and Navy Central Adjudication Facilities in
September 2010. In addition to these assessment tools, in 2010 DOD,
OMB, ODNI, and OPM developed 15 metrics that assess the timeliness
and quality of investigations, adjudications, reciprocity, and automation.
The quality metrics, in turn, can be used to gauge progress and assess
the quality of the personnel security clearance process. These metrics
represented positive developments that could contribute to greater
visibility over the clearance process.

Having assessment tools and performance metrics in place is a critical
initial step toward instituting a program to monitor and independently
validate the effectiveness and sustainability of corrective measures. The
combination of congressional reporting requirements, the strategic
framework, and the development of quality metrics, will help ensure
transparency throughout the reform effort. It is important not only to have
metrics but to use them to guide implementation. By using metrics for
timeliness, DOD was able to show progress over time that helped build
momentum to reach the final goal.




Page 11                                                          GAO-12-815T
                            DOD’s security clearance reform effort aligned with our criteria for
Continuing Executive        removal from the high-risk list in fiscal year 2011. However, security
Branch Leadership           clearance reform extends beyond DOD throughout the executive branch.
                            This is evidenced by the oversight structure, through the Performance
and Management              Accountability Council, and broad executive branch participation in the
Attention May               reform effort. Building on the factors for reforming the security process
Enhance the Security        that we have reported in the past, continued leadership and attention,
                            such as continuing to monitor and update outcome-focused performance
Clearance Reform            measures, seeking opportunities to enhance efficiency and managing
Efforts                     costs, and ensuring a strong requirements determination process, may
                            enhance the security clearance reform effort. 21



Implementing, Monitoring,   DOD has developed tools to monitor quality as well as participated in the
and Updating Outcome-       development and tracking of quality metrics for OPM’s investigations and
Focused Performance         DOD’s adjudications through the Performance Accountability Council. We
                            view the development of quality metrics as a positive step towards
Measures                    creating greater visibility over the quality of the clearance process and
                            identifying specific quantifiable targets linked to goals that can be
                            measured objectively. Moreover, leaders and others need to use these
                            metrics to gauge progress toward improvements. Further, the
                            development of performance measures related to the security clearance
                            process by the Performance Accountability Council aligns with our
                            previous recommendation to develop outcome-focused performance
                            measures to continually evaluate the progress of the reform effort. 22 We
                            have also previously reported on the importance of continually assessing
                            and evaluating programs as a good business practice, including
                            evaluating metrics to help ensure that they are effective and updated
                            when necessary. 23 As a result, it is important to sustain the momentum of
                            the reform and that DOD and OPM complete implementation of the




                            21
                               GAO, Personnel Clearances: Key Factors for Reforming the Security Clearance
                            Process, GAO-08-776T (Washington, D.C.: May 22, 2008).
                            22
                               GAO, Personnel Security Clearances: An Outcome-Focused Strategy Is Needed to
                            Guide Implementation of the Reformed Clearance Process, GAO-09-488 (Washington,
                            D.C.: May 19, 2009).
                            23
                              GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1
                            (Washington, D.C.: November 1999).




                            Page 12                                                                  GAO-12-815T
quality tools and metrics so that the executive branch can demonstrate
progress in improving the quality of investigations and adjudications.

Leaders of the reform effort have consistently stated that implementation
of reform will be incremental, and therefore, it is important that the
information necessary to capture performance is up-to-date. The
Performance Accountability Council quality metrics were developed
subsequent to the issuance of the 2010 Strategic Framework, which
articulates the goals of the security and suitability process reform. As a
result, the 2010 Strategic Framework did not include a detailed plan or
guidance for the implementation of the quality metrics. Further, the
May 31, 2010 memorandum in which the Performance Accountability
Council detailed its metrics did not discuss how often the metrics will be
reexamined for continuous improvement. Moreover, according to DOD,
the tools and metrics to assess quality have not been fully implemented.
For example, while DOD has implemented its RAISE tool for investigation
quality, it is not being used by other executive branch agencies—
including OPM, which conducts the investigations and would be the
appropriate agency to take actions to improve investigation quality—
although the Joint Reform Team is considering using it in the future.
Without these tools and metrics the executive branch will be unable to
demonstrate progress in improving quality.

Emphasis on quality in clearance processes should promote positive
outcomes, including more reciprocity among agencies in accepting each
others’ clearances. Building quality throughout clearance processes is
important, but government agencies have not paid the same attention to
quality as they have to timeliness. The emphasis on timeliness is due in
part to the requirements and objectives established in IRTPA regarding
the speed with which clearances should be completed. Our work has
repeatedly called for more emphasis on quality.

As previously noted, IRTPA required an annual report of progress and
key measurements as to the timeliness of initial security clearances in
February of each year from 2006 through 2011. It specifically required
those reports to include the periods of time required for conducting
investigations, adjudicating cases, and granting clearances. IRTPA
required the executive branch to implement a plan by December 2009 in
which, to the extent practical, 90 percent of initial clearances were
completed within 60 days, on average. In its initial reports, the executive
branch reported only on the average of the fastest 90 percent of
clearances and excluded the slowest 10 percent. We previously reported
that full visibility was limited by the absence of comprehensive reporting


Page 13                                                          GAO-12-815T
of initial clearance decisions timeliness. 24 Consistent with our
recommendation, the executive branch began reporting on the remaining
10 percent in its 2010 and 2011 reports. However, the IRTPA requirement
for the executive branch to annually report on its timeliness expired last
year. More recently, in 2010, the Intelligence Authorization Act of 2010
established a new requirement 25 that the President annually report the
total amount of time it takes to process certain security clearance
determinations for the previous fiscal year for each element of the
Intelligence Community. 26

The Intelligence Authorization Act of 2010 requires, among other things,
annual reports from the President to Congress that include the total
number of active security clearances throughout the United States
government, to include both government employees and contractors. Its
timeliness reporting requirement, however, applies only to the elements of
the Intelligence Community. Unlike the IRTPA reporting requirement, the
requirement to submit these annual reports does not expire. Further, the
Intelligence Authorization Act requires two additional one-time reports:
first, a report to Congress by the President including metrics for
adjudication quality, and second, a report to the congressional
intelligence committees by the Inspector General of the Intelligence
Community on reciprocity. The report containing metrics for adjudication
quality summarizes prior information on developed tools and performance
measures; however, it does not provide additional information on the
implementation or update of the performance measures that were



24
  GAO, Personnel Clearances: Key Factors to Consider in Efforts to Reform Security
Clearance Processes. GAO-08-352T. Washington, D.C.: February 27, 2008.
25
  Section 367 of the Intelligence Authorization Act for Fiscal Year 2010, Pub. L. No. 111-
259 (2010), established new annual reporting requirements in section 506H of the
National Security Act of 1947 (50 U.S.C. § 415a-10).
26
   The Intelligence Community comprises 17 components: the National Security Agency,
National Geospatial-Intelligence Agency, National Reconnaissance Office, Defense
Intelligence Agency, Army Intelligence, Navy Intelligence, Marine Corps Intelligence, Air
Force Intelligence (Air Force Intelligence, Surveillance, and Reconnaissance), Office of
the Director of National Intelligence, Central Intelligence Agency, Department of
Homeland Security (Office of Intelligence and Analysis), Department of State (Bureau of
Intelligence and Research), Department of the Treasury (Office of Intelligence and
Analysis), Federal Bureau of Investigation (National Security Branch), Drug Enforcement
Agency (Office of National Security Intelligence), U.S. Coast Guard (Intelligence and
Criminal Investigations), and Department of Energy (Office of Intelligence and
Counterintelligence).




Page 14                                                                       GAO-12-815T
identified in the May 2010 memorandum on quality metrics. Additionally,
according to an ODNI official, the report on reciprocity has not been
provided, although these reports were required 180 days after the law
was enacted on Oct 7, 2010.

The Intelligence Authorization Act of 2010 reporting requirement on
reciprocity—an agency’s acceptance of a background investigation or
clearance determination completed by any authorized investigative or
adjudicative agency—is the first time the executive branch has been
required to report on this information since the reform effort began.
Further, in 2010 we reported that although there are no governmentwide
metrics to comprehensively track when and why reciprocity is granted or
denied, agency officials stated that they routinely take steps to honor
previously granted security clearances. 27 We found that agencies do not
consistently document the additional steps they have taken prior to
granting a reciprocal clearance. For example, the Navy keeps electronic
documentation, the Department of Energy and the Department of the
Treasury keep paper documentation, and the Army and the Air Force do
not maintain any documentation on the additional steps taken to accept a
previously granted security clearance. Consequently, there is no
consistent tracking of the amount of staff time spent on the additional
actions that are taken to honor a previously granted security clearance.

In addition, agencies do not consistently and comprehensively track the
extent to which reciprocity is granted. OPM has a metric to track
reciprocity, but this metric captures limited information, such as numbers
of requested and rejected investigations, but not the number of cases in
which a previously granted security clearance was or was not honored.
Similarly, the metrics proposed by the Performance Accountability
Council do not track the extent to which reciprocity is or is not ultimately
honored. For example, metrics proposed by the Performance
Accountability Council, such as the number of duplicate requests for
investigations, percentage of applications submitted electronically,
number of electronic applications submitted by applicants but rejected by
OPM as unacceptable because of missing information or forms, and
percentage of fingerprint submissions determined to be “unclassifiable” by
the Federal Bureau of Investigation, provide useful information but do not


27
   GAO, Personnel Security Clearances: Overall Progress Has Been Made to Reform the
Governmentwide Security Clearance Process, GAO-11-232T (Washington, D.C.: Dec. 1,
2010).




Page 15                                                                 GAO-12-815T
                         track the extent to which reciprocity is or is not ultimately honored.
                         Without comprehensive, standardized metrics to track reciprocity, and
                         documentation of the process, decision makers lack a complete picture of
                         the extent to which reciprocity is granted and the challenges to honoring
                         previously granted security clearances.

                         To further improve governmentwide reciprocity, in 2010 we recommended
                         that the Deputy Director of Management, OMB, in the capacity as Chair of
                         the Performance Accountability Council, develop comprehensive metrics
                         to track reciprocity and then report the findings from the expanded
                         tracking to Congress. 28 OMB generally concurred with our
                         recommendation, stating that the Performance Accountability Council is
                         working to develop these additional metrics. According to a 2011 report
                         on security clearance performance metrics, the executive branch is
                         making progress toward developing metrics to track reciprocity
                         specifically with the intelligence community agencies. 29 We are
                         encouraged by the Performance Accountability Council’s development of
                         quality metrics, which include some metrics for tracking reciprocity. These
                         are positive steps that can contribute to greater visibility of the clearance
                         process, but these measures have not yet been fully implemented or their
                         effectiveness assessed.


Enhancing Efficiencies   Our previous work has highlighted the importance of the executive branch
and Managing Costs       enhancing efficiency and managing costs related to the reform effort. For
                         example, in 2008, we noted that one of the key factors to consider in
                         current and future reform efforts was the long-term funding
                         requirements. 30 Further, in 2009, we found that reform-related reports did
                         not detail what reform objectives require funding, how much they will cost,
                         or where funding will come from. 31 Furthermore, the reports did not


                         28
                            GAO, Personnel Security Clearances: Progress Has Been Made to Improve Timeliness
                         but Continued Oversight Is Needed to Sustain Momentum, GAO-11-65 (Washington,
                         D.C.: November 19, 2010).
                         29
                           Office of the Director of National Intelligence, 2011 Report on Metrics for Security
                         Clearance Adjudication Quality (January 17, 2012)
                         30
                            GAO. DOD Personnel Clearance: Improved Annual Reporting Would Enable More
                         Informed Congressional Oversight. GAO-08-350 (Washington, D.C.: February 13, 2008).
                         31
                           GAO. Personnel Security Clearances: An Outcome-Focused Strategy Is Needed to
                         Guide Implementation of the Reformed Clearance Process. GAO-09-488 (Washington,
                         D.C.: May 19, 2009).




                         Page 16                                                                        GAO-12-815T
estimate potential cost savings resulting from the streamlined process. At
that time, senior reform leaders stated that cost estimates had not been
completed by the Joint Reform Team or the agencies affected by reform
as it was too early. Accordingly, we recommended that reform leaders
issue a strategic framework that contained the long-term funding
requirements of reform, among other things. Consequently, in February
2010, the Performance Accountability Council issued a strategic
framework that responded to our recommendation; however, that
framework did not detail funding requirements. Instead, it noted that DOD
and OPM would cover costs for major information technology
acquisitions.

As reform leaders, through the Performance Accountability Council,
consider changes to the current clearance processes, they should ensure
that Congress is provided with the long-term funding requirements
necessary to implement any such reforms. Those funding requirements to
implement changes to security clearance processes are necessary to
enable the executive branch to compare and prioritize alternative
proposals for reforming the clearance processes. For example, DOD
officials told us that it was unable to conduct quality assessment of
adjudications during fiscal year 2011 due to lack of funding. In addition,
DOD officials noted that the department is using its tool to assess the
quality of investigations. However, there is no evidence that this tool is
being used by other agencies to assess the quality of investigations.
Given current fiscal constraints, identifying the long-term costs is critical
for decision-makers to compare and prioritize alternative proposals for
completing the transformation of the security clearance process. Without
information on longer-term funding requirements necessary to implement
the reform effort, Congress lacks the visibility it needs to fully assess
appropriations requirements. We most recently reported on two areas of
opportunity for which the executive branch may be able to identify
efficiencies: information technology and investigation and adjudication
case management and processes. 32




32
   GAO, Background Investigations: The Office of Personnel Management Needs to
Improve Transparency of Its Pricing and Seek Cost Savings, GAO-12-197 (Washington,
D.C.: Feb. 2012).




Page 17                                                                 GAO-12-815T
Information Technology Is a   In February 2012, we reported that information technology investments
Primary Cost Driver in the    were one of OPM’s background investigations programs’ three main cost
Security Clearance Process    drivers. 33 While these investments represent less than 10 percent of
                              OPM’s fiscal year 2011 reported costs, they have increased more than
                              682 percent over 6 years (in fiscal year 2011 dollars), from about $12
                              million in fiscal year 2005 to over $91 million in fiscal year 2011. 34
                              Moreover, we reported that OPM’s investigation process reverts its
                              electronically-based investigation back into paper-based files. In
                              November 2010, the Deputy Director for Management of the Office of
                              Management and Budget testified that OPM now receives over 98
                              percent of investigation applications electronically, yet we observed that it
                              is continuing to use a paper-based investigation processing system and
                              converts electronically submitted applications to paper. OPM officials
                              stated that the paper-based process is required because a small portion
                              of their customer agencies do not have electronic capabilities.
                              Furthermore, OPM’s process has not been studied to identify efficiencies.
                              As a result, OPM may be simultaneously investing in process
                              streamlining technology while maintaining a less-efficient and duplicative
                              paper-based process. We recommended that OPM take actions to
                              identify process efficiencies, including its use of information technology to
                              complete investigations, which could lead to cost savings within its
                              background investigation processes. OPM concurred with our
                              recommendation and commented that these actions also reinforce a
                              Federal Investigative Services priority and that the agency will continue to
                              map its process to achieve maximum process efficiencies and identify
                              potential cost savings. In commenting on our final report, OPM stated in a
                              May 25, 2012 letter to us that it is taking a number of actions that could
                              lead to cost savings within its background investigation process. For
                              example, OPM noted it is conducting a study of business processes
                              identifying time savings and efficiencies for future Federal Investigative
                              Services’ business processes which will conclude by December 2013.




                              33
                                   GAO-12-197.
                              34
                                 For fiscal years 2005 to 2007, information technology costs were primarily for the
                              operation and maintenance of OPM’s information technology for processing background
                              investigations; after fiscal year 2008 and beyond, according to officials information
                              technology costs increased as a result of Federal Investigative Services’ modernization
                              effort, known as EPIC modernization.




                              Page 18                                                                     GAO-12-815T
Case Management and    In February 2012, as part of our annual report on opportunities to reduce
Adjudication Process   duplication, overlap and fragmentation, we reported that multiple
Efficiencies Could     agencies have invested in or are beginning to invest in potentially
Reduce Duplication     duplicative, electronic case management and adjudication systems
                       despite governmentwide reform effort goals that agencies leverage
                       existing technologies to reduce duplication and enhance reciprocity. 35
                       According to DOD officials, DOD began the development of its Case
                       Adjudication Tracking System in 2006 and, as of 2011, invested a total of
                       $32 million to deploy the system. The system helped DOD achieve
                       efficiencies with case management and an electronic adjudication module
                       for secret level cases that did not contain issues, given the volume and
                       types of adjudications performed. According to DOD officials, after it
                       observed that the Case Adjudication Tracking System could easily be
                       deployed to other agencies at a low cost, the department intended to
                       share the technology with interested entities across the federal
                       government. For example, the Department of Energy is piloting the
                       electronic adjudication module of DOD’s system, and, according to DOD
                       officials, the Social Security Administration is also considering adopting
                       the system. In addition to DOD, Department of Justice officials said they
                       began developing a similar system in 2007 at a cost of approximately $15
                       million. In an effort to better manage the adjudication portion of the
                       suitability and security clearance process, agencies have transitioned or
                       plan to transition from a paper-based to an electronic adjudication case-
                       management system. Although the investment in electronic case-
                       management systems will likely lead to process efficiencies, agencies
                       may not be leveraging adjudication technologies in place at other
                       executive branch agencies to minimize duplication.

                       Five other agencies are also developing or seeking funds to develop
                       systems with similar capabilities. 36 With multiple agencies developing
                       individual case-management systems, these agencies may be at risk of
                       duplicating efforts and may fail to realize cost savings. DOD officials
                       suggested that opportunities may exist to leverage their case-
                       management technology. However, DOD officials explained that agencies



                       35
                          GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and
                       Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington,
                       D.C.: Feb. 28, 2012).
                       36
                          One of these other agencies, the National Reconnaissance Office, is itself a component
                       of DOD.




                       Page 19                                                                     GAO-12-815T
would have to initially invest approximately $300,000 for implementation,
plus any needed expenditures related to customizations, and long-term
support and maintenance, which could require approximately $100,000
per year.

Officials from OPM, one of the five other agencies developing or seeking
funds to develop similar systems, explained that they plan to develop an
electronic case-management system that is synchronized with its
governmentwide background investigations system that would be
available for their customer agencies to purchase. OPM released a
request for information to evaluate the options for this system. DOD
responded to OPM’s request for information by performing a comparative
analysis of its own case-management system and said that it believes its
system meets the needs set out in OPM’s request for information.
However, OPM officials said that DOD’s system would cost too much
money for smaller agencies to adopt, so OPM plans to continue exploring
other options that would allow customer agencies access to their
electronic case-management system without the need to make an
expensive initial investment. Additionally, OPM officials said that their
effort is intended to promote process efficiency by further integrating OPM
with its more than 100 customer agencies. However, some OPM
customer agencies, including DOD, which makes up approximately 75
percent of OPM’s investigation workload, expressed concern that such a
system would likely be redundant to currently available case-
management technology. Further, any overhead costs related to the
development of an OPM system would be incorporated into OPM’s
operating costs, which could affect investigation prices.

The investment in electronic case-management systems aligns with the
reform effort’s goal to automate information technology capabilities to
improve the timeliness, efficiency, and quality of existing security
clearance and suitability determinations systems. It also will likely lead to
process efficiencies; however, agencies may be unclear how they might
achieve cost savings through leveraging adjudication technologies in
place at other executive branch agencies. In its March 2009 Enterprise
Information Technology Strategy, the Joint Reform Team stated that
agencies will leverage existing systems to reduce duplication and
enhance reciprocity. Moreover, the Performance Accountability Council is
positioned to promote coordination and standardization related to the
suitability and security clearance process through issuing guidance to the
agencies. The reform effort’s strategic framework includes cost savings in
its mission statement, but this framework lacks specificity regarding how
agencies might achieve costs savings. Without specific guidance, the


Page 20                                                           GAO-12-815T
                          opportunities to minimize duplication and achieve cost savings may be
                          lost. Therefore, in 2012 we recommended that OMB as the Chair of the
                          Performance Accountability Council expand and specify reform-related
                          guidance to help ensure that reform stakeholders identify opportunities for
                          cost savings, such as preventing duplication in the development of
                          electronic case management.OMB concurred with our recommendation. 37


A Sound Requirements      In February 2008 and in subsequent reports, we have noted the
Process for Determining   importance of having a sound requirements determination process for
Required Clearances and   security clearances. Specifically, a sound requirements determination
                          process may help ensure that workload and costs are not higher than
Level of Clearances May   necessary. Further, the Performance Accountability Council’s reformed
Reduce Costs              security clearance process identified determining if a position requires a
                          security clearance as the first step of the process. Specifically, the
                          clearance process begins with establishing whether a position requires a
                          clearance, and if so, at what level. The numbers of requests for initial and
                          renewal clearances and the levels of such clearance requests are two
                          ways to look at outcomes of requirements setting in the clearance
                          process. As of October 2010, the Director of National Intelligence
                          reported that 3.9 million 38 federal employees (military and civilian) and
                          contractors hold security clearances. Moreover, OPM reported that its
                          cost to conduct background investigations for much of the executive
                          branch outside the intelligence agencies increased about 79 percent from
                          about $602 million in fiscal year 2005 to over $1.1 billion in fiscal year
                          2011.

                          In our prior work, DOD personnel, investigations contractors, and industry
                          officials told us that the large number of requests for investigations could
                          be attributed to many factors. For example, they ascribed the large
                          number of requests to the heightened security concerns that resulted
                          from the September 11, 2001, terrorist attacks. They also attributed the
                          large number of investigations to an increase in the operations and
                          deployments of military personnel and to the increasingly sensitive
                          technology that military personnel, government employees, and
                          contractors come in contact with as part of their jobs. Having a large
                          number of cleared personnel can give the military services, agencies, and


                          37
                               GAO-12-197.
                          38
                               These are the latest available data.




                          Page 21                                                          GAO-12-815T
industry a great deal of flexibility when assigning personnel, but the
investigative and adjudicative workloads that are required to provide
clearances and that flexibility further tax the clearance process.

A change in the higher level of clearances being requested also increases
the investigative and adjudicative workloads. For example, top secret
clearances must be renewed twice as often as secret clearances (i.e.,
every 5 years versus every 10 years). More specifically, the average
investigative report for a top secret clearance takes about 10 times as
many investigative staff hours as the average investigative report for a
secret clearance. As a result, the investigative workload increases about
20-fold. Additionally, the adjudicative workload increases about 4-fold,
because in our previous work, DOD officials estimated that investigative
reports for a top secret clearance took about twice as long to review as an
investigative report for a secret clearance. Further, a top secret clearance
needs to be renewed twice as often as the secret clearance. In August
2006, OPM estimated that approximately 60 total staff hours are needed
for each investigation for an initial top secret clearance and 6 total staff
hours are needed for the investigation to support a secret or confidential
clearance. The doubling of the frequency along with the increased effort
to investigate and adjudicate each top secret reinvestigation adds costs
and workload for the government.

For fiscal year 2012, OPM’s standard base prices are $4,005 for an
investigation for an initial top secret clearance; $2,711 for an investigation
to renew a top secret clearance, and either $228 or $260 for an
investigation for a secret clearance. 39 As we reported in February 2012,
these base prices can increase if triggered by the circumstances of a
case, such as issues related to credit or criminal history checks. For
example, in 2011, DOD officials stated that the prices contained in OPM’s
Federal Investigative Notices are not always reflective of the amount
DOD actually pays for an investigation, as a result of these
circumstances. Further, the cost of getting and maintaining a top secret
clearance for 10 years is almost 30 times greater than the cost of getting
and maintaining a secret clearance for the same period. For example, an
individual getting a top secret clearance for the first time and keeping the
clearance for 10 years would cost the government a total of $6,716 in
current year dollars ($4,005 for the initial investigation and $2,711 for the



39
     These billing rates are published in OPM’s annual Federal Investigative Notices.




Page 22                                                                         GAO-12-815T
reinvestigation after the first 5 years). In contrast, an individual receiving a
secret clearance and maintaining it for 10 years would result in a total
cost to the government of $228 ($228 for the initial clearance that is good
for 10 years). Requesting a clearance for a position in which it will not be
needed, or in which a lower level clearance would be sufficient, will
increase investigative workload and thereby costs unnecessarily. We are
currently reviewing the process that the executive branch uses to
determine whether a position requires a security clearance for the
Ranking Member of the House Committee on Homeland Security, and the
expected issuance date for this report is this summer.


In conclusion, Mr. Chairman, Mr. Johnson, and Members of the
Subcommittee, as evidenced by our removal of the DOD’s security
clearance program from our high-risk list, we are strongly encouraged by
the progress that the Performance Accountability Council, and in
particular, DOD, has made over the last few years. DOD has shown
progress by implementing recommendations, improving overall
timeliness, and taking steps to integrate quality into its processes. The
progress that has been made with respect to the overall governmentwide
reform efforts would not be possible without committed and sustained
leadership of Congress and by the senior leaders involved in the
Performance Accountability Council as well as their dedicated staff.
Continued oversight and stewardship of the reform efforts is the
cornerstone to sustaining momentum and making future progress. As the
executive branch continues to move forward to enhance the suitability
and security clearance reform, the actions to monitor quality and enhance
efficiency will be key to enhance the progress made on timeliness to date.

Chairman Akaka, Ranking Member Johnson, and Members of the
Subcommittee, this concludes my prepared statement, and I would be
pleased to answer any questions that you may have. Thank you.

For further information on this testimony, please contact Brenda S.
Farrell, Director, Defense Capabilities and Management, who may be
reached at (202) 512-3604. Contact points for our Congressional
Relations and Public Affairs offices may be found on the last page of this
statement. GAO staff who made key contributions to this testimony
include Lori Atkinson (Assistant Director), Grace Coleman, Sara Cradic,
James Krustapentus, Gregory Marchand, Jillena Roberts, and Amie
Steele.




Page 23                                                             GAO-12-815T
Related GAO Products
             Related GAO Products




             Background Investigations: Office of Personnel Management Needs to
             Improve Transparency of Its Pricing and Seek Cost Savings.
             GAO-12-197. Washington, D.C.: February 28, 2012.

             GAO’s 2011 High-Risk Series: An Update. GAO-11-394T. Washington,
             D.C.: February 17, 2011.

             High-Risk Series: An Update. GAO-11-278. Washington, D.C.: February
             16, 2011.

             Personnel Security Clearances: Overall Progress Has Been Made to
             Reform the Governmentwide Security Clearance Process. GAO-11-232T.
             Washington, D.C.: December 1, 2010.

             Personnel Security Clearances: Progress Has Been Made to Improve
             Timeliness but Continued Oversight Is Needed to Sustain Momentum.
             GAO-11-65. Washington, D.C.: November 19, 2010.

             DOD Personnel Clearances: Preliminary Observations on DOD’s
             Progress on Addressing Timeliness and Quality Issues. GAO-11-185T.
             Washington, D.C.: November 16, 2010.

             Personnel Security Clearances: An Outcome-Focused Strategy and
             Comprehensive Reporting of Timeliness and Quality Would Provide
             Greater Visibility over the Clearance Process. GAO-10-117T.
             Washington, D.C.: October 1, 2009.

             Personnel Security Clearances: Progress Has Been Made to Reduce
             Delays but Further Actions Are Needed to Enhance Quality and Sustain
             Reform Efforts. GAO-09-684T. Washington, D.C.: September 15, 2009.

             Personnel Security Clearances: An Outcome-Focused Strategy Is
             Needed to Guide Implementation of the Reformed Clearance Process.
             GAO-09-488. Washington, D.C.: May 19, 2009.

             DOD Personnel Clearances: Comprehensive Timeliness Reporting,
             Complete Clearance Documentation, and Quality Measures Are Needed
             to Further Improve the Clearance Process. GAO-09-400. Washington,
             D.C.: May 19, 2009.

             High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January
             2009.



             Page 24                                                     GAO-12-815T
Related GAO Products




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.

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

Employee Security: Implementation of Identification Cards and DOD’s
Personnel Security Clearance Program Need Improvement.
GAO-08-551T. Washington, D.C.: April 9, 2008.

Personnel Clearances: Key Factors to Consider in Efforts to Reform
Security Clearance Processes. GAO-08-352T. Washington, D.C.:
February 27, 2008.

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

DOD Personnel Clearances: Improved Annual Reporting Would Enable
More Informed Congressional Oversight. GAO-08-350. Washington, D.C.:
February 13, 2008.

DOD Personnel Clearances: Delays and Inadequate Documentation
Found for Industry Personnel. GAO-07-842T. Washington, D.C.: May 17,
2007.

High-Risk Series: An Update. GAO-07-310. Washington, D.C.: January
2007.

DOD Personnel Clearances: Additional OMB Actions Are Needed to
Improve the Security Clearance Process. GAO-06-1070. Washington,
D.C.: September 28, 2006.

DOD Personnel Clearances: New Concerns Slow Processing of
Clearances for Industry Personnel. GAO-06-748T. Washington, D.C.:
May 17, 2006.

DOD Personnel Clearances: Funding Challenges and Other Impediments
Slow Clearances for Industry Personnel. GAO-06-747T. Washington,
D.C.: May 17, 2006.




Page 25                                                      GAO-12-815T
           Related GAO Products




           DOD Personnel Clearances: Government Plan Addresses Some Long-
           standing Problems with DOD’s Program, But Concerns Remain.
           GAO-06-233T. Washington, D.C.: November 9, 2005.

           DOD Personnel Clearances: Some Progress Has Been Made but Hurdles
           Remain to Overcome the Challenges That Led to GAO’s High-Risk
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           High-Risk Series: An Update. GAO-05-207. Washington, D.C.: January
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           DOD Personnel Clearances: Preliminary Observations Related to
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