DOD Personnel Clearances: Additional Steps Can Be Taken to Reduce Backlogs and Delays in Determining Security Clearance Eligibility for Industry Personnel

In its 31 U.S.C. 720 response dated June 23, 2004, DOD partially concurred with this recommendation. DOD reported that it has numerous plans underway to improve the personnel security investigation process from end-to-end. These plans align changes with functional responsibilities. In November 2002, DOD decided to divest the PSI function and procure these services from OPM. This decision came from the Secretary's Business Improvement Council under the Senior Executive Council, and was reflected in the President's Budget for FY 2004. The transfer of PSIs to OPM and the corresponding transformation of DSS were intended to result in the permanent elimination of the investigative and adjudicative backlogs, and reduce delay in determining eligibility for clearances. The transfer of the DSS investigative workforce would give OPM a federal investigative strength to accomplish the most critical and sensitive investigations. At the same time, OPM would be increasing its contractor base of investigators to ensure sufficient investigative resources for the federal investigative workload. Investigations are a core competency of OPM, so by moving all DOD investigations to OPM and centralizing the contracting function for investigations, capacity would be leveraged, resulting in decreasing investigative timelines. The DSS collaborative adjudication support (CAS) would provide common services for all of the DOD CAFs. Such services would include acquisition and contracting oversight. This DSS organization also would leverage DSS' relationship with industry as the single industry CAF for all industry clearances, including interim, suitability, and trustworthiness determinations. The adjudicative process would cover SCI accesses. The effort was intended to streamline the DOD adjudicative process, facilitating faster adjudicative timelines. As of May 2005, it was too soon to realize any benefits from transfer of the PSI function to OPM. OPM estimated that 35-day service for priority investigations could be provided by mid-2005 as long as no more than 10 percent of DOD investigations were priority requests. The CAS element at DSS was not yet fully staffed and was in the process of defining its missions and functions and establishing its organizational structure. The initiative to establish a single industry CAF has been accomplished. As of January 2006, CAS had been fully staffed. A formal CAS missions and functions statement had not yet been developed pending selection of a permanent CAS Director. As of October 2006, CAS management was under review by the Acting Director. As of March 2007, a CAS review was conducted and DSS reorganized CAS into the Personnel Security Clearance Office (PSCO). Mission and functions statement had been drafted, and PSCO had centralized expertise at the HQ element to provide action officers to work process improvement issues. As of October 23, 2007, OUSD(I) had published a memorandum (August 31, 2007) that designated DSS as the central operational manager of personnel security workload projections, funding, and quality of investigation results oversight. A copy is in the case file. The PSCO Director was in place on March 19, 2007, and DSS hired chiefs for the Clearance Oversight and Clearance Liaison offices, which are responsible for the centralized operational management of DOD PSI requirements and monitoring of PSI funding for DOD components, and the coordination of DOD-wide requirements for quality issues and PSI processing issues with OPM. Organizational staffing for the CLO would be complete and COO staffing at an operational level by end of October 2007. GAO's accomplishment report GAO-06-842A indicates that DOD's clearance-related issues were addressed in a governmentwide plan. More recently, OMB's February 2008 annual report to the Congress maintains that the timelines of the initial clearances is improving.

In its 31 U.S.C. 720 response dated June 23, 2004, DOD concurred with this recommendation. DOD identified specific planned actions on each initiative to decrease the backlog and delays. In December 2004, the President approved the phased periodic reinvestigation (PRR). In February 2005, DOD provided OPM with a comprehensive policy document with the criteria to be used for the PRR and directed that all investigative providers conducting TS/SCI PRs for DOD were to use the modified standard. A single, industry central adjudication facility (CAF) was established at DSS. The DSS academy was developing a comprehensive adjudication course for use across DOD. DSS was working with PERSEREC to develop an improved methodology for projecting industry workload. The Automated Continuing Evaluation System (ACES) underwent beta testing until August 2005. The system was expected to be implemented in July 2006 as a supplement to the regular periodic reinvestigation. OPM implemented the PRR at the beginning of FY 2006 and DOD components were provided guidance. The Joint Personnel Adjudication System's (JPAS) module to verify and validate all investigation requests became operational in FY 2006. As of January 2006, expansion of scope of an industry CAF and associated training was delayed pending coordination of DOD 5200.2-R. A comprehensive adjudication course had not yet been initiated due to funding limitations. PERSEREC could not come up with a better way for projecting industry clearance requirements than what was currently used by DSS. In July 2006, PSWG published a standard Program of Instruction for standardized adjudicator training throughout the security community (see D-2001-065). As of October 2006, DSS was working with the USD(I) Comptroller to obtain FY 2007 funds to build and deploy Automated Records Checks (ARC), and ACES Production System, and to obtain FY 2008-2013 funds to enhance and maintain the system. DUSD(I)(CI&S) funded a project in FY 2007 to write business rules enabling electronic review of completed investigations. As of March 2007, DSS developed a Personnel Security Program Improvement Plan to fix the process in DOD. No funding for the plan was obtained in FY 2007; however, PBD 704 provided O&M funding for ARC in FY 2008-2013, but there were no RDT&E dollars. DOD continued to make progress on developing business rules and identifying requirements with OPM to implement an Adjudication Decision Support (ADS) system to automatically process reports of completed personnel security investigations, known as electronic reports for adjudication (eRFA). ADS research on processing TS investigations was expected to have draft results in FY 2007. Regarding automated clean case screening for personnel security investigative results, as of October 2007, DOD: (1) released a research report on "ADS System Automated Approval Estimates for NACLC Investigations," regarding initial and reinvestigations for access eligibility at the SECRET and CONFIDENTIAL levels, (2) provided input to the DOD/DNI Security Clearance Process Reform Team on coordinating ADS business rules with related developments in ARC and ACES, (3) was evaluating an ADS method for automated screening of reinvestigations for continued TOP SECRET access eligibility, and (4) successfully validated an alternative ADS option for automatic screening of NACLC cases using OPM's current "no issues" and "no actionable issues" clean case codes. Business rule development regarding SSBI cases and a final validation of ADS rules for NACLC cases were delayed because OPM was not able to provide DOD with a requested case sample of OPM's new electronic Distributed Investigative File (DIF) format. The Army CAP provided PERSEREC with Army DIF case samples ADS research in September 2007. GAO accomplishment report GAO-05-1179 documented that DOD's PRR initiative was implemented. Also, more recent information shows that DOD is implementing its ACES in a pilot study for the Army.