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United States Government Accountability Office: 
Washington, DC 20548: 

December 19, 2008: 

Congressional Committees: 

Subject: DOD Personnel Clearances: Preliminary Observations about 
Timeliness and Quality: 

The enclosed briefing provides our preliminary assessment of the 
timeliness and quality of the Department of Defense's (DOD) personnel 
security clearance program. These findings are based on an ongoing 
engagement that we have been conducting since February 2008 under the 
Comptroller General's authority to conduct evaluations on his own 
initiative.[Footnote 1] In 2009, we plan to issue a report providing 
more details regarding these findings. In response to a draft of this 
briefing report, DOD provided written comments and the Office of 
Personnel Management (OPM) provided comments via email. Our summary and 
evaluation of DOD's and OPM's comments are included in enclosure II and 
DOD's written comments are reprinted in their entirety in enclosure 
III. We are addressing this product to you at your request due to your 
continued interest in the DOD personnel security clearance program. 

We are sending copies of this letter to the appropriate congressional 
committees. We are also sending copies to the Director of the Office of 
Management and Budget; the Secretary of Defense; the Under Secretary of 
Defense for Intelligence; and the Director of the Office of Personnel 
Management. This letter will also be available at no charge on our Web 
site at [hyperlink, http://www.gao.gov]. 

Should you or your staff have any questions concerning this letter, 
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. 

Signed by: 

Brenda S. Farrell:
Director:
Defense Capabilities and Management: 

Enclosures: 

List of Congressional Committees: 

The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate: 

The Honorable Silvestre Reyes:
Chairman:
House Permanent Select Committee on Intelligence: 

The Honorable Anna G. Eshoo:
Chairman:
The Honorable Darrell Issa:
Ranking Member:
Subcommittee on Intelligence Community Management:
House Permanent Select Committee on Intelligence: 

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

United States Senate:
The Honorable Solomon P. Ortiz:
Chairman:
The Honorable J. Randy Forbes:
Ranking Member:
Subcommittee on Readiness:
Committee on Armed Services:
House of Representatives: 

The Honorable Edolphus Towns:
Chairman The Honorable Brian Bilbray:
Ranking Member:
Subcommittee on Government Management, Organization, and Procurement:
Committee on Oversight and Government Reform:
House of Representatives: 

[End of section] 

Enclosure I: 

Department of Defense Personnel Clearances: Preliminary Observations 
about Timeliness and Quality: 

Briefing for Congressional Committees: 

December 19, 2008: 

Briefing Overview: 

* Introduction: 

* Background: 

* Objectives: 

* Scope and Methodology: 

* Summary: 

* Preliminary Observations: 

* Agency Comments: 

* GAO Contact and Acknowledgments: 

* Appendix I: Scope and Methodology: 

* Related GAO Products: 

[End of section] 

Introduction: 

In fiscal year 2008, the Department of Defense (DOD) approved personnel 
security clearances for about 630,000 requests for initial and renewal 
confidential, secret, and top secret clearances for DOD’s military, 
civilian, and industry personnel. 

Since 2005, the Office of Management and Budget (OMB) has been 
responsible for implementing policy relating to determination of 
eligibility for access to classified information and reporting annually 
to Congress on progress in improving the clearance process. 

The Office of Personnel Management’s (OPM) federal and contract 
investigators conduct most of DOD’s clearance investigations and DOD 
adjudicators use their reports to make clearance eligibility decisions. 

We placed DOD’s personnel security clearance program on our high-risk 
list in 2005 and continued that designation in 2007, our most recent 
update, because of a variety of problems including delays and 
incomplete documentation of initial top secret clearances. 

The executive branch established a Joint Reform Team, consisting of 
OMB, DOD, OPM, and the Office of the Director of National Intelligence, 
in June 2007 to reform the security clearance process for DOD and other 
agencies. 

[End of section] 

Background: The Six Phases of DOD’s Security Clearance Process: 

Figure 1: Six Phases in DOD’s Personnel Security Clearance Process: 

[Refer to PDF for image] 

1. Requirements setting: DOD determines if a position requires the 
subject to access classified information, and if so, the level of 
clearance needed. 

2. Application submission: Subject provides application materials and 
security officer reviews and submits request for investigation. 

3. Investigation: OPM, or one of its contractors, conducts and 
investigation and forwards an investigative report to an adjudication 
facility. 

4. Adjudication: On the basis of information in the investigative 
report, DOD adjudicators determine eligibility to access classified 
information. 

5. Appeal: If a clearance is denied or revoked, subject can appeal the 
adjudicative decision. 

6. Clearance updating: If subject has long-term need to access 
classified information, clearance is updated: top secret, 5 years; 
secret, 10 years; and confidential, 15 years. 

Source: GAO analysis of DOD-provided information. 

Note: In our current audit, we measure the timeliness and completeness 
of the investigation and adjudication phases (numbers 3 and 4). 

[End of figure] 

Background: Intelligence Reform and Terrorism Prevention Act of 2004: 

The Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) 
[Footnote 2] currently requires adjudicative agencies to make a 
determination on at least 80 percent of all applications for a security 
clearance within 120 days, on average, after the date of receipt of the 
application, with no longer than: 

* 90 days allotted for the investigation and; 

* 30 days allotted for the adjudication. 

IRTPA also requires the executive branch to implement a plan by 
December 17, 2009, under which adjudicative agencies, to the extent 
practical, must make a determination on at least 90 percent of all 
applications for a security clearance within 60 days, on average, after
the date of receipt of the application, with no longer than: 

* 40 days allotted for the investigation and; 

* 20 days allotted for the adjudication. 

Background: Investigative Standards: 

OPM federal or contract investigators conduct clearance investigations
by using governmentwide standards.[Footnote 3] The types of information 
gathered in an investigation depend on the clearance level. For initial 
top secret clearances, investigators gather information in the 
following 14 areas: 

1. completion of forms (e.g., complete personnel security 
questionnaire); 

2. national agency databases (e.g., FBI) check; 
3. national agency database check of spouses; 
4. date and place of birth; 
5. citizenship; 
6. education; 
7. employment; 
8. social references; 
9. former spouse interview; 
10. residence; 
11. financial review; 
12. local agency databases (e.g., local law enforcement) check; 
13. public records review (e.g., bankruptcy); 
14. subject interview. 

OPM investigators also follow OPM’s internal guidance on fulfilling 
these requirements. 

Background: Adjudicative Guidelines: 

Once an investigation is complete, DOD adjudicators review the
investigative report and decide whether to grant clearance eligibility 
to the subject. To make their determination, federal requirements 
[Footnote 4] specify that adjudicators consider the following separate 
adjudicative guidelines: 

1. allegiance to the United States; 
2. foreign influence; 
3. foreign preference; 
4. sexual behavior; 
5. personal conduct; 
6. financial considerations; 
7. alcohol consumption; 
8. drug involvement; 
9. emotional, mental, and personality disorders; 
10. criminal conduct; 
11. security violations; 
12. outside activities; 
13. misuse of information technology systems. 

Background: Adjudication Documentation: DOD Adjudicative Regulation: 

DOD regulation 5200.2R[Footnote 5] requires that adjudicators maintain 
a written or automated record of each favorable and unfavorable 
adjudicative determination, including the rationale underlying the 
determination when a clearance applicant has potential security 
concerns. DOD interprets rationale to include, at a minimum, the 
identification of the applicable adjudicative guidelines and the 
associated mitigating factors. 

Background: Four Key Factors to Consider for Clearance Reform: 

As we have previously noted,[Footnote 6] ongoing governmentwide 
security clearance reform efforts could benefit from establishing a 
coherent mission and integrating strategic goals, among other best 
practices we have identified. 

In addition, we have previously noted that the following four key 
factors should be part of clearance reform efforts: 

1. Ensuring a strong requirements-determination process. 

2. Building quality in all clearance processes to promote positive 
outcomes, such as facilitating reciprocity—in which agencies accept 
clearances granted by other federal agencies. 

3. Developing additional metrics to provide a fuller picture of 
clearance processes. 

4. Including the long-term funding requirements of security clearance
reform. 

Background: Ongoing Security Clearance Reform Efforts: 

The Joint Reform Team issued an implementation plan in December
2008 to guide ongoing clearance reform efforts. 

This plan includes some elements that are consistent with best 
practices and key factors that GAO has previously identified. 
Specifically, the plan identifies the following metrics: 

* Timeliness metrics for various components of the clearance process; 

* Metrics for both investigation and adjudication quality,[Footnote 7] 
and; 

* Initial steps to measure clearance reciprocity. 

Still much remains to be done to implement the reforms and sustain the 
recent progress of the Joint Reform Team. 

GAO has ongoing work being conducted at the request of the Chairman of 
the House Permanent Select Committee on Intelligence and Chairwoman of 
the of the committee’s Subcommittee on Intelligence Community 
Management to evaluate the Joint Reform Team’s Efforts. 

[End of section] 

Objectives: 

Our ongoing audit work addresses the following questions: 

1. How timely is the process for determining eligibility for DOD 
initial confidential, secret, and top secret personnel security 
clearances? 

2. How complete is the documentation of investigations for DOD initial 
top secret personnel security clearances? 

3. How complete is the documentation of adjudications for DOD initial 
top secret personnel security clearances? 

[End of section] 

Scope and Methodology: 

To assess the timeliness of DOD’s personnel security clearance process, 
we reviewed the timeliness requirements specified in federal law and in 
OMB performance goals laid out in annual reports. We measured the 
timeliness of personnel security clearances using OPM and DOD data for 
448,255 initial confidential, secret, and top secret clearances 
adjudicated in fiscal year 2008 by the central adjudication facilities 
of the U.S. Army, U.S. Navy, U.S. Air Force, and the Defense Industrial 
Security Clearance Office. We conducted electronic testing on these 
data and found that they were sufficiently reliable for the purposes of 
this product. 

To assess the completeness of investigation and adjudication 
documentation, respectively, we reviewed federal investigative 
standards, OPM’s internal guidance, and adjudicative guidelines. We 
collected and reviewed a random sample of 100 OPM investigative reports 
and associated adjudication documentation for initial top secret 
clearances granted to DOD military, civilian, and industry personnel in 
July 2008 by the central adjudication facilities of the U.S. Army, U.S. 
Navy, and U.S. Air Force. We focused on top secret clearances because 
we have identified documentation problems with this clearance level in 
previous work; top secret clearance investigations require information 
to be gathered for 14 investigative standards; and granting top secret 
clearances enables subjects to access information that, if improperly 
disclosed, could cause exceptionally grave damage to national security. 
Our review of this sample enabled us to estimate the level of 
completeness of the investigation and adjudication documentation of the 
approximately 3,500[Footnote 8] initial top secret clearances favorably 
adjudicated at these central adjudication facilities in July 2008. The 
estimates from this sample have a margin of error of plus or minus 10 
percent or less. 

We conducted this performance audit from February 2008 through December 
2008 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 assessment based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our assessment 
based on our audit objectives. 

[End of section] 

Summary: 

While many clearances continue to experience delays, OMB, DOD, and OPM 
have made significant progress in meeting IRTPA’s requirements by 
making a determination in fiscal year 2008 on at least 80 percent of 
initial confidential, secret, and top secret personnel security 
clearances in less than an average of 120 days. 

The vast majority of favorably adjudicated initial top secret clearance 
investigative reports OPM provided to DOD adjudicators in July 2008 
were missing at least one type of required documentation. 

Required documentation of DOD’s application of federal adjudicative 
guidelines was incomplete in an estimated 22 percent of files for 
initial top secret clearances adjudicated in July 2008. 

We provided our draft briefing report to the Department of Defense 
(DOD) and the Office of Personnel Management (OPM). In response to this 
draft, we received written comments from DOD (see enclosure III) and 
comments via email from OPM which we summarize below. Throughout our 
briefing report, we also incorporated our responses to each agency’s 
comments where appropriate. 

* In his comments to our briefing report the Under Secretary of Defense 
for Intelligence (USDI) stated that while our observations of the 
timeliness and quality of the DOD personnel security program are fair,
DOD does not share some of the same concerns that we identified in our 
briefing report. 

* In email comments to our briefing report, OPM’s Federal Investigative 
Services Division (FISD) agreed with our observation that DOD and OPM 
have made significant progress in improving the timeliness of the DOD 
personnel security clearance program. However, OPM did not concur with 
our observations concerning the completeness of the documentation of 
initial top secret personnel security clearance investigations. 

[End of section] 

Preliminary Observations: Timeliness: 

While many clearances continue to experience delays,OMB, DOD, and OPM 
have made significant progress[Footnote 9] in meeting IRTPA 
requirements by making a determination in fiscal year 2008 on at least 
80 percent of initial personnel security clearances in less than an 
average of 120 days: 

Table 1: Average Days[A] to Complete 80 Percent of DOD Initial 
Personnel Security Clearances[B] in Fiscal Year 2008: 

Clearance type: Initial confidential, secret, and top secret; 
Average days to complete 80% of initial clearances, Government 
requirement: 120 Days; 
Average days to complete 80% of initial clearances, GAO’s analysis: 87 
Days. 

[A] We measured clearance timeliness of the investigation and 
adjudication phases from the date that OPM receives a completed 
clearance application to the adjudication date. 

[B] These initial confidential, secret, and top secret clearances were 
adjudicated at the central adjudication facilities of the U.S. Army, 
U.S. Navy, U.S. Air Force, and the Defense Industrial Security 
Clearance Office during fiscal year 2008. 

Source: GAO analysis of OPM and DOD data. 

[End of table] 

However, DOD and OMB officials have noted that the existing clearance 
process is not likely to allow DOD and other agencies to meet IRTPA’s 
2009 timeliness requirements, which require the implementation of a 
plan by December 2009 under which, to the extent practical, at least 90 
percent of initial personnel security clearance determinations take no 
longer than 60 days, on average. To meet these more demanding 
timeliness requirements, the executive branch established a Joint 
Reform Team to reform the security clearance process for DOD and other
agencies. 

Delays in completing clearances increase the length of time a subject 
holds an interim clearance: 

* while awaiting initial clearances, DOD facilities grant most subjects 
interim clearances, which require a limited review of a subject’s 
background: 
- national agency checks; 
- local file checks at a subject’s facility (e.g., personnel records, 
security files); 
- SF-86 (i.e., the information the subject provides). 

Delays in the clearance process increase the time that subjects, who 
might ultimately be denied a clearance, have access to classified 
information. 

Preliminary Observations: Completeness of Investigation Documentation: 

The vast majority of OPM-provided investigative reports which DOD 
adjudicators used to grant initial top secret clearances in July 2008 
were missing some required documentation. 

* We estimated that 87 percent[Footnote 10] of about 3,500 OPM-provided 
investigative reports that DOD adjudicators used to grant initial top
secret clearances in July 2008 were missing at least one type of
documentation required by federal investigative standards and OPM’s 
internal guidance. 

The types of missing investigation items ranged from subject
interviews[Footnote 11]—which OPM officials told us is an important 
element of a clearance investigation because the subject is a key 
source of information—to record checks at a subject’s place(s) of 
employment and residence(s). 

Most frequently, investigative reports were missing completed security 
clearance forms, verification of all employment, and information from 
the required number of social references. Additionally, some reports 
had multiple incomplete investigative items. 

Figure 2: Estimated Percentage of Incomplete OPM Investigation Reports 
by Investigative Standard: 

[Refer to PDF for image] 

This figure is a vertical bar graph depicting the following data: 

Investigative standard: Employment; 
Percentage of incomplete investigative reports: 33%. 

Investigative standard: Social references; 
Percentage of incomplete investigative reports: 32%. 

Investigative standard: Forms; 
Percentage of incomplete investigative reports: 31%. 

Investigative standard: National records; 
Percentage of incomplete investigative reports: 18%. 

Investigative standard: Residence; 
Percentage of incomplete investigative reports: 17%. 

Investigative standard: Education; 
Percentage of incomplete investigative reports: 16%. 

Investigative standard: Subject interview; 
Percentage of incomplete investigative reports: 12%. 

Investigative standard: Local records; 
Percentage of incomplete investigative reports: 9%. 

Investigative standard: Spouse records; 
Percentage of incomplete investigative reports: 8%. 

Investigative standard: Financial; 
Percentage of incomplete investigative reports: 3%. 

Investigative standard: Former spouse; 
Percentage of incomplete investigative reports: 2%. 

Note: These estimates have a margin of error, based on a 95-percent 
confidence interval, within +/- 10 percent, and are based on our review 
of a random sample of 100 OPM investigative reports favorably 
adjudicated by the central adjudication facilities of the U.S. Army, 
U.S. Navy, and U.S. Air Force in July 2008. All estimates are rounded 
to the nearest whole percentage. 

[End of figure] 

Incomplete investigations may cause delays, increase costs, and
introduce risk in the adjudication process. 

* DOD adjudicators are sometimes required to perform work of an
investigative nature because of incomplete investigative reports,
which increases the amount of time required and the costs involved
to make an adjudicative determination. 
- For example, DOD adjudicators told us that when investigation
reports lack complete law enforcement database checks and financial 
verification information they follow up by conducting additional 
criminal history and financial verification (e.g., obtaining missing 
bankruptcy records). 

* An incomplete investigative report introduces risk into the clearance
process because adjudicators do not have all of the required 
investigative information about a clearance subject when making a
decision to grant a personnel security clearance. 

Because the federal investigative standards do not assign a level of
importance to each investigative requirement, we did not make 
evaluative judgments about the importance of one missing investigative
item over another during our review. We assessed only whether the
documentation for each required investigative item was complete. In
addition, we did not make judgments about the adequacy of the 
investigative reports to support decisions made by DOD adjudicators to
grant or deny clearances. 

* OPM officials reviewed and concurred with a subset of our assessment.
- In their written response, officials from OPM’s Federal Investigative
Services Division’s Quality Management Group reviewed eight of the 
sample investigative reports and concurred with our assessment that 
documentation for at least one item required by federal investigative 
standards or OPM’s internal guidance was missing and an unresolved 
issue of a potential security concern was present in one report. 

Preliminary Observations: Completeness of Adjudication Documentation: 

Required documentation of DOD’s application of federal adjudicative 
guidelines was incomplete in some files for the initial top secret 
clearances adjudicated in July 2008. 

Figure 3: Estimated Percentage of Incomplete Adjudication Files by 
Adjudicative Guideline: 

[Refer to PDF for image] 

This figure is a vertical bar graph depicting the following data: 

Adjudicative guideline: Foreign influence; 
Percentage of incomplete adjudicative files: 9%. 

Adjudicative guideline: Financial considerations; 
Percentage of incomplete adjudicative files: 9%. 

Adjudicative guideline: Criminal conduct; 
Percentage of incomplete adjudicative files: 5%. 

Adjudicative guideline: Personal conduct; 
Percentage of incomplete adjudicative files: 2%. 

Adjudicative guideline: Alcohol consumption; 
Percentage of incomplete adjudicative files: 1%. 

Adjudicative guideline: Drug involvement; 
Percentage of incomplete adjudicative files: 1%. 

Source: GAO analysis of DOD adjudication reports. 

Note: These estimates have a margin of error, based on a 95-percent 
confidence interval, within +/- 8 percent and are based on our review 
of a random sample of 100 DOD initial top secret clearances favorably 
adjudicated at the central adjudication facilities of the U.S. Army, 
U.S. Navy, and U.S. Air Force in July 2008—some of which included
multiple incomplete items. All estimates are rounded to the nearest 
whole percentage. 

[End of figure] 

We estimated that 22 percent[Footnote 12] of about 3,500 adjudication 
files that DOD granted in July 2008 were missing documentation required 
by a DOD regulation. 

In addition, DOD adjudicators granted clearance eligibility using 
incomplete OPM-provided investigation reports. 

* As we noted above, we estimated that DOD adjudicators granted
eligibility to 87 percent[Footnote 13] of initial top secret clearances 
in July 2008 based on incomplete investigative reports. 

* We did not make evaluative judgments about the importance of one
missing investigative item over another. 

* Further, we did not evaluate the merit of the DOD adjudicators’
decisions to grant clearances. 

Adjudicators and adjudication facility leadership reviewed and 
concurred with a subset of the adjudicative files we reviewed, and we
incorporated their feedback in our analysis. 

The use of incomplete adjudicative files could: 

* increase the risk of adjudicators missing patterns of behavior in 
subsequent clearance renewals since adjudicators may refer to prior 
adjudication files as part of their decision-making process and; 

* undermine efforts to achieve clearance reciprocity (an agency 
accepting a clearance awarded by another agency). 

Additionally, the use of incomplete clearance documentation in the 
investigative and adjudicative phases may increase the risk of 
unauthorized disclosure of classified information. 

• As we have previously reported,[Footnote 14] DOD and other agencies, 
in the past, have paid little attention to quality metrics, which can 
provide a more complete picture of the clearance process. 

[End of section] 

Agency Comments: 

In response to a draft of this briefing report, DOD provided written 
comments and OPM provided comments via email. Our summary and 
evaluation of DOD’s and OPM’s comments are included in enclosure II, 
and DOD’s written comments are reprinted in their entirety in enclosure 
III. 

[End of section] 

GAO Contact and Acknowledgements: 

Should you or your staff have any questions on the matters discussed in
this briefing, please contact Brenda S. Farrell at (202) 512-3604 or
farrellb@gao.gov. 

Key contributors to this report were David E. Moser, Assistant Director;
James D. Ashley; Catherine Gelb; Mae Jones; Shvetal Khanna; James P. 
Klein; Caryn E. Kuebler; Ronald La Due Lake; Dolores McGhee; Gregory A. 
Marchand; and Thomas R. Predmore. 

[End of section] 

Appendix I - Scope and Methodology: 

Timeliness: 

To assess the extent to which the process for determining security 
clearance eligibility for Department of Defense (DOD) initial 
confidential, secret, and top secret security clearances is timely, we: 

* Measured the timeliness of 448,255 initial clearances—at the 
confidential, secret, and top secret levels—adjudicated in fiscal year 
2008 by the adjudication facilities of the U.S. Army, U.S. Navy, U.S. 
Air Force, and Defense Industrial Security Clearance Office. 

* Analyzed the data to measure whether initial clearances were 
completed according to statutory requirements specified in the 
Intelligence Reform and Terrorism Prevention Act (IRTPA) of 2004. 

* Obtained and reviewed data from the Joint Personnel Adjudication 
System, DOD’s clearance database, and the Personnel Investigation 
Processing System, the Office of Personnel Management’s (OPM) 
investigations database. We conducted electronic testing on these data 
and found that they were sufficiently reliable for the purposes of this 
product. 

Investigation Documentation Completeness: 

To determine the extent of documentation completeness of the 
investigative reports for DOD initial top secret security clearances, 
we: 

* Selected a random sample of OPM-provided investigative reports for 
100 initial top secret personnel security clearances for DOD military, 
civilian, and industry personnel working on DOD contracts that were 
favorably adjudicated during July 2008 at the central adjudication 
facilities of the U.S. Army, U.S. Navy, and U.S. Air Force. We sampled 
from 3,993 clearances and found that some of the reports, such as 
conditionally granted clearances, were out of the scope of our audit 
since we assessed only final determinations. Therefore, we estimate, 
that the number of clearances that DOD granted at the U.S. Army, U.S.
Navy, and U.S. Air Force central adjudication facilities in July 2008 
was 3,500 (+/- 300 clearances), based on a 95 percent confidence level. 

* Developed a data collection instrument based on the federal 
investigative standards and OPM’s internal guidance. We solicited and 
incorporated feedback on this data collection instrument from officials 
at OPM’s Federal Investigative Services Division, DOD’s Personnel 
Security Research Center, and the Air Force’s central adjudication 
facility. 

* Used the instrument to categorize an investigative item in the 
selected investigative report as incomplete if the report did not 
contain all of the required documentation for that item. 
- For example, we categorized the employment area as incomplete if 
investigators did not document an actual or attempted check of the 
subject’s employee record(s) or interviews of employment references 
such as supervisors and coworkers. 

* Reviewed a subset of the data collection instruments and associated 
investigative reports initially completed by team members for data 
reliability purposes by having a second team member independently 
verify information. 

Adjudication Documentation Completeness: 

To determine the extent of documentation completeness in the 
adjudication files, we: 

* Selected the same random sample of 100 OPM investigative reports and 
associated adjudication documentation for 100 initial top secret 
clearances for DOD military, civilian, and industry personnel that were 
favorably adjudicated during July 2008 at the central adjudication 
facilities of the U.S. Army, U.S. Navy, and U.S. Air Force. 

* Developed a data collection instrument based on the federal 
adjudicative guidelines and solicited feedback from DOD’s Office of the 
Under Secretary of Defense for Intelligence and the Defense Personnel 
Security Research Center. 

* Engaged adjudicators in GAO’s security office to review the sample 
adjudication files and apply the data collection instrument to them. 

* Engaged adjudicators in GAO’s security office to independently review 
a random subset of the completed data collection instruments and 
adjudication files to ensure the reliability of our data. 

We conducted this performance audit from February 2008 through December 
2008 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 assessment based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our assessment 
based on our audit objectives. 

[End of section] 

Related GAO Products: 

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

Personnel Clearances: Questions for the Record Regarding Security 
Clearance Reform. [hyperlink, http://www.gao.gov/products/GAO-08-965R]. 
Washington, D.C.: July 14, 2008. 

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

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

DOD Personnel Clearances: Questions for the Record Related to the 
Quality and Timeliness of Clearances. [hyperlink, 
http://www.gao.gov/products/GAO-08-580R]. Washington, D.C.: March 25, 
2008. 

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

DOD Personnel Clearances: DOD Faces Multiple Challenges in Its Efforts 
to Improve Clearance Processes for Industry Personnel. [hyperlink, 
http://www.gao.gov/products/GAO-08-470T. Washington, D.C.: Feb. 13, 
2008. 

DOD Personnel Clearances: Improved Annual Reporting Would Enable More 
Informed Congressional Oversight. [hyperlink, 
http://www.gao.gov/products/GAO-08-350]. Washington, D.C.: February 13, 
2008. 

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

DOD Personnel Clearances: Additional OMB Actions Are Needed to Improve 
the Security Clearance Process. [hyperlink, 
http://www.gao.gov/products/GAO-06-1070]. Washington, D.C.: September 
28, 2006. 

[End of section] 

[End of Enclosure I] 

Enclosure II: Agency Comments and Our Evaluation: 

We provided our draft briefing report to the Department of Defense 
(DOD) and the Office of Personnel Management (OPM). In response to this 
draft, we received written comments from DOD (see enclosure II) and 
comments via email from OPM which we summarize below. Throughout our 
briefing report, we also incorporated our responses to each agency's 
comments where appropriate. 

Department of Defense: 

In his comments to our briefing report the Under Secretary of Defense 
for Intelligence (USDI) stated that while our observations of the 
timeliness and quality of the DOD personnel security program are fair, 
DOD does not share some of the same concerns that we identified in our 
briefing report. 

In response to our observation that 80 percent of initial DOD 
clearances completed in fiscal year 2008 took an average of 87 days to 
complete the investigation and adjudication phases, the USDI noted that 
at the end of October 2008, 80 percent of DOD's initial security 
clearances were completed within an average of 76 days. As we state in 
our briefing report, we measured the average time to complete 448,255 
initial clearances completed in fiscal year 2008. We did not measure 
the time to complete clearances in fiscal year 2009. Our analysis 
provides a representative assessment of the timeliness of clearances 
completed in fiscal year 2008. 

In response to our observation that the vast majority of favorably 
adjudicated initial top secret investigative reports OPM provided to 
DOD adjudicators in July 2008 were missing at least one type of 
required documentation, the USDI stated that DOD adjudicators use a 
risk-managed approach when granting security clearances, to ensure that 
critical DOD positions are filled. The USDI stated that he is confident 
in DOD's risk-managed approach for adjudicating security clearances, 
even when the investigative reports are not complete. He also described 
the steps involved in this approach. As we state in our final briefing 
report, we did not evaluate the merit of DOD adjudicators' decisions to 
grant clearances using the risk-management guidelines the USDI 
describes. As we also state in our briefing report, we did not make 
evaluative judgments about the importance of one missing investigative 
item over another in our review. We assessed only whether the 
documentation for each required investigative item was complete in the 
reports that DOD adjudicators used to make their clearance eligibility 
decisions. Our preliminary observation is that DOD adjudicators granted 
eligibility to an estimated 87 percent of initial top secret clearances 
in July 2008 based on incomplete investigative reports. 

In response to our observation regarding incomplete documentation of 
adjudicative decisions, the USDI stated that it is essential that DOD 
adjudicators appropriately document adjudicative rationale. Further, 
the USDI noted that by the end of 2009, DOD plans to deploy 
enhancements to the Joint Personnel Adjudication System that will 
facilitate and standardize the documentation process throughout DOD. We 
agree that appropriate documentation of the adjudicative rationale is 
essential, because, as we noted in the briefing report, the use of 
incomplete clearance documentation may increase the risk of 
adjudicators missing patterns of behavior in subsequent clearance 
renewals since adjudicators may refer to prior adjudication files as 
part of their decision-making process and may undermine efforts to 
achieve clearance reciprocity (an agency accepting a clearance awarded 
by another agency). 

In response to our observation in our draft report that DOD has not 
developed quality metrics, the USDI stated that the quality of 
investigations and adjudications are of paramount importance and 
described the development of two tools to assess clearance quality that 
DOD plans to begin using in March 2009. We revised our final briefing 
report to reflect the USDI's additional information provided. 
Furthermore, as we noted in the briefing report, the Joint Reform 
Team's December 2008 clearance reform implementation plan includes some 
elements which are consistent with best practices and key factors that 
we have previously identified. Specifically, the plan includes metrics 
for both investigation and adjudication quality and initial steps to 
measure clearance reciprocity. While much remains to be done to 
implement the reforms and sustain the recent progress of the Joint 
Reform Team, we are encouraged by the inclusion of these elements in 
the Joint Reform Team's implementation plan. 

Office of Personnel Management: 

In email comments to our briefing report, OPM's Federal Investigative 
Services Division (FISD) agreed with our observation that DOD and OPM 
have made significant progress in improving the timeliness of the DOD 
personnel security clearance program. However, OPM did not concur with 
our observations concerning the completeness of the documentation of 
initial top secret personnel security clearance investigations. 

In response to our observations about the completeness of the 
documentation of investigations for DOD initial top secret personnel 
security clearances, OPM stated that it provided us with investigation 
policy guidance prior to the construction of our data collection 
instrument to assess investigation documentation completeness. OPM 
stated that the instrument was detailed, but accurately represented the 
requirements and complexity of the investigative process, and OPM 
further stated that it believes this instrument would have provided 
more accurate findings--indicating that OPM believes we used a 
different data collection instrument to assess investigation 
documentation completeness. However, the instrument, which we developed 
collaboratively, is the instrument we ultimately used to assess 
completeness. 

In response to our statement that OPM reviewed and concurred with a 
subset of our analysis of 8 investigation reports, OPM stated that it 
disagreed with most of our findings about individual investigative 
items in those 8 reports. Further, OPM stated that these 8 reports met 
the federal investigative standards and supported DOD's adjudicative 
needs. In the review of these reports, OPM provided an explanation for 
why some required items were missing based on the complexity of the 
investigation process and the unique aspects of the individual 
investigation. However, in OPM's written response to our analysis, it 
concurred with our assessment that documentation for at least one item 
required by the federal investigative standards or OPM's internal 
guidance was missing in each of these reports. Moreover, as DOD 
adjudicators review investigative reports, they consider adjudicative 
guidelines which are separate from the federal investigative standards 
to make their determination. As we note in our final briefing report, 
we did not make judgments about the adequacy of the investigative 
reports to support an adjudicative determination. Instead, we 
categorized these reports as incomplete if they did not contain all of 
the documentation required by the federal investigative standards and 
OPM's internal guidance. 

In addition, OPM responded to our observations about the completeness 
the documentation of initial top secret investigations by providing 
reasons that some required information was missing from the 8 
investigative reports we reviewed with OPM. As we state in our briefing 
report, we discuss one reason for an incomplete investigative item. We 
recognize that there are additional reasons for missing information in 
investigative reports and will discuss these reasons in more depth in 
the report we will issue in 2009. 

Further, OPM indicated that during a meeting, we acknowledged the 
several reasons OPM discussed for missing information and stated that 
an investigative file would be considered complete if it included 
documentation explaining the reasons OPM was unable to complete a 
required element. OPM stated that OPM agreed to this measurement. 
However, at this meeting we stated only one aspect of our methodology 
and made no agreement with OPM about our full methodological approach. 

In response to our observation that an estimated 31 percent of 
investigative reports were missing forms, OPM stated that the forms do 
not affect the adjudicative process and are not required elements of 
the investigation report. We disagree. The federal investigative 
standards for initial top secret clearances require the completion of 
forms, including the personnel security questionnaire (Standard Form 
86), applicable releases, and supporting documentation. In our review, 
we found that nearly a third of the investigative reports included 
incomplete forms. 

[End of Enclosure II] 

Enclosure III: Comments from the Department of Defense: 

Under Secretary Of Defense: 
Intelligence: 
5000 Defense Pentagon: 
Washington, DC 20301-5000: 

December 18, 2008: 

Ms. Brenda S. Farrell: 
Director: 
Defense Capabilities and Management: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Ms. Farrell: 

Thank you for the opportunity to review the draft briefing for 
Congressional Committees, Department of Defense Personnel Clearances: 
Preliminary Observations about Timeliness and Quality (GAO-09-261R). 
The observations outlined in the briefing are a fair assessment of the 
timeliness and quality of the Department's personnel security program: 
however, DoD does not share some of the same concerns. The enclosure 
provides specific feedback on the Department's adjudicative decisions 
and quality assessment program. Should you have additional questions or 
concerns, please contact my point of contact, Ms. Becky Allen, at (703) 
604-1173 or rebecca.allen@osd.mil. 

Sincerely, 

Signed by: 

James R. Clapper, Jr. 

Enclosure: As stated: 

Department of Defense Response: 

GAO draft briefing for Congressional Committees: 

Department of Defense Personnel Clearances: Preliminary Observations 
about Timeliness and Quality (GAO-09-261R): 

GAO Observation: While many clearances continue to experience delays, 
OMB, DOD, and OPM have made significant progress in meeting IRTPA 
requirements by making a determination on an average of 80 percent of 
initial confidential, secret, and top secret personnel security 
clearances within 120 days. 

DoD Response: I endorse and support your observation that significant 
progress has been made to improve the timeliness of the security 
clearance process as outlined in your report. It is important to note 
that the timeliness data in this brief does not reflect current 
performance levels. At the end of October 2008, 80% of the Department's 
initial security clearances were completed within an average of 76 
days, which is 11 days faster than outlined in your brief. The 
Department anticipates further improvements in the timeliness of 
security clearance process as Joint Security Suitability Reform Team 
reform efforts are fully completed and implemented. 

GAO Observation: The vast majority of favorably adjudicated initial top 
secret clearance investigative reports OPM provided to DOD adjudicators 
in July 2008 were missing at least one type of required documentation. 

DoD Response: The Department of Defense is committed to safeguarding 
classified information and follows procedures outlined in EO 12968, 
"Access to National Classified Information." According to EO 12968 and 
the Office of Management and Budget (OMB) Memorandum, "Reciprocal 
Recognition of Existing Personnel Security Clearances," dated November 
14, 2007, adjudicators may consider risk when granting interim security 
clearances or clearances based on a deviation from National 
investigative standards. Pursuant to 10 U.S.C., the Secretary of 
Defense must deploy a fully operational force. In many cases 
operational readiness hinges on the ability to access classified 
information. To ensure critical operational mission positions are 
filled, the Department assumes a risk managed approach when granting 
security clearances. I am confident in our risk managed approach for 
adjudicating security clearances, even when the investigative reports 
are not complete. 

The risk managed approach includes a process of gathering preliminary 
information to mitigate risk and considered against the National 
adjudicative guidelines, and includes: 

* a review of local security and personnel files. 

* a review of the completed National Agency Check, which includes the 
Federal Bureau of investigation (FBI) fingerprint check. 

* a consideration of personnel who have had continuous long-term access 
to classified information, investigative history and performance. 

* an incorporation of the Office of Personnel Management (OPM) practice 
of reporting derogatory information that may develop during the 
investigative process. 

* the employment of risk managed procedures at the agency or command 
level for personnel granted interim security clearances, or for 
personnel granted a security clearances based on an exception, 
condition, or deviation (the aforementioned factors are weighed against 
National adjudicative standards). 

GAO Observation: Required documentation of adjudicative rationale in 
DOD adjudication files was incomplete in about 20 percent of the 
initial top secret clearance files adjudicated in July 2008. 

DoD Response: It is essential that the Department appropriately 
document adjudicative rationale. The Department will deploy 
enhancements to the Joint Personnel Adjudication System (JPAS) that 
will facilitate and standardize the documentation process throughout 
DoD. This enhancement is scheduled for deployment by the end of 2009. 

GAO Observation: DOD and has not developed quality metrics, which can 
provide a more complete picture of the clearance process. 

DoD Response: Because the quality of investigations and security 
clearance adjudications are of paramount importance, the Department 
developed and successfully demonstrated tools last year that assess 
both investigative and adjudicative quality. The Rapid Assessment of 
Incomplete Security Evaluations (RAISE) is used to assess investigative 
quality and the Review of Adjudication Documentation Accuracy and 
Rationales (RADAR) is used to assess adjudicative quality. The 
Department will begin using RAISE by the end of March 2009. Use of 
RADAR will begin the following year. 

[End of Enclosure III] 

Footnotes: 

[1] 31 U.S.C. § 717. 

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

[3] 32 C.F.R. §§ 147.18 - 147.24 (2008). While these standards were in 
place at the time of our review, the executive branch issued revised
investigative standards in December 2008. 

[4] 32 C.F.R. §§ 147.3 - 147.15 (2008). The federal investigative 
standards support adjudicative decisions but are distinct from the 
adjudicative guidelines. 

[5] DOD Regulation 5200.2-R, DOD Personnel Security Program (January 
1987). 

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

[7] The implementation plan calls for developing a survey to measure 
the quality of investigations and a similar tool to measure adjudication
quality. 

[8] We sampled from 3,993 clearances and found that some of the reports 
were out of the scope of our audit. Therefore, we estimate that the
number of clearances that DOD granted at the U.S. Army, U.S. Navy, and 
U.S. Air Force central adjudication facilities in July 2008 was 3,500 
(+/- 300 clearances), based on a 95 percent confidence level. 

[9] In 2007, we reported that a sample of 2,259 initial clearances for 
DOD industry personnel took an average of 325 days to complete the 
investigation and adjudication phases. 

[10] This estimate has a margin of error, based on a 95-percent 
confidence interval, of +/- 9 percent. 

[11] Missing subject interviews in the investigative reports we 
reviewed were the result of the subject’s deployment. 

[12] This estimate has a margin of error, based on a 95 percent 
confidence interval, of +/- 10 percent. 

[13] This estimate has a margin of error, based on a 95 percent 
confidence interval, of +/- 9 percent. 

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

[End of section] 

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