This testimony discusses the key recommendations from the two reports we recently released, which include (1) the need for a fully developed strategic framework for the reform process that includes outcome-focused performance measures to show progress and (2) more transparency in annually reporting to Congress on the timeliness and quality of the clearance process. This testimony is based on our review of the Joint Reform Team's plans, as well as our work on DOD's security clearance process, which includes reviews of clearance-related files and interviews of senior officials at the Office of Management and Budget (OMB), DOD, Office of the Director of National Intelligence (ODNI), and OPM. In addition, this statement is based on key practices and implementation steps for mergers and organizational transformations. We conducted our work on both reports between March 2008 and May 2009 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Although the high-level leadership and governance structure of the current reform effort distinguish it from previous efforts, it is difficult to gauge progress of reform, or determine if corrective action is needed, because the council, through the Joint Reform Team, has not established a method for evaluating the progress of the reform efforts. Without a strategic framework that fully addresses the long-standing security clearance problems and incorporates key practices for transformation--including the ability to demonstrate progress leading to desired results--the Joint Reform Team is not in a position to demonstrate to decision makers the extent of progress that it is making toward achieving its desired outcomes, and the effort is at risk of losing momentum and not being fully implemented. In addition to limited visibility over timeliness of clearances, the executive branch's annual reports to Congress on the personnel security clearance process have provided decision makers with limited data on quality, and the executive branch has missed opportunities to make the clearance process transparent to Congress. For example, we independently estimated that 87 percent16 of about 3,500 investigative reports prepared by OPM that DOD adjudicators (employees who decide whether to grantclearance to an applicant based on the investigation and other information) used to make clearance decisions, for initial top secret clearances adjudicated in July 2008, were missing required documentation. Because neither OPM nor DOD measures the completeness of their investigative reports or adjudicative files, both agencies are limited in their ability to explain the extent to which or the reasons why some documents are incomplete. Incomplete documentation may lead to increases in the time needed to complete the clearance process and in the overall costs of the process and may reduce the assurance that appropriate safeguards are in place to prevent DOD from granting clearances to untrustworthy individuals. We have stated that timeliness alone does not provide a complete picture of the clearance process and emphasized that attention to quality could increase reciprocity--accepting another federal entity's clearances--and the executive branch, though not required to include information on quality in its annual reports, has latitude to report appropriate information. We are encouraged that, while the 2009 report did not provide any data on quality, unlike previous reports it did identify quality metrics that the executive branch proposes to collect.