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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: 

For Release on Delivery: 
Expected at 10:30 a.m. EST:
Tuesday, November 16, 2010: 

DOD Personnel Clearances: 

Preliminary Observations on DOD's Progress on Addressing Timeliness 
and Quality Issues: 

Statement of Brenda S. Farrell, Director:
Defense Capabilities and Management: 

GAO-11-185T: 

GAO Highlights: 

Highlights of GAO-11-185T, 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: 

In light of longstanding problems with delays and backlogs, Congress 
mandated personnel security clearance reforms through the Intelligence 
Reform and Terrorism Prevention Act of 2004 (IRTPA), which requires, 
among other things, that executive agencies meet objectives for the 
timeliness of the investigative and adjudicative phases of the 
security clearance process. Since 2005, the Department of Defense’s 
(DOD) clearance program has been on GAO’s high-risk list due to 
timeliness delays and GAO continued that designation in 2007 and 2009 
also due to concerns about quality. 

Based on prior and ongoing work, this statement addresses DOD’s 
progress in (1) reducing the timeliness of initial personnel security 
clearances at DOD and (2) building quality into the processes used to 
investigate and adjudicate security clearances. GAO reviewed 
Performance Accountability Council timeliness data and has begun a 
preliminary analysis of available DOD data, examined key clearance 
reform documents, and conducted interviews with DOD and the 
Performance Accountability Council officials about timeliness and 
efforts to improve the quality of investigations and adjudications. 
GAO plans to continue examining the timeliness and quality of 
personnel security clearances in DOD. This work will help inform the 
Comptroller General’s high risk update decision in January 2011. 

What GAO Found: 

DOD, which comprises the vast majority of clearances, has made 
significant progress in reducing delays in making personnel security 
clearance decisions and meeting statutory timeliness objectives since 
GAO first designated DOD’s personnel security clearance program as a 
high risk area in 2005. In 2007, GAO found that initial clearances for 
DOD industry personnel took an average of 325 days to complete. With 
the passage of IRTPA in 2004, timeliness requirements were established 
in law and executive branch agencies were required to make decisions 
on at least 80 percent of initial clearances within an average of 120 
days. In 2008, GAO found that DOD had made significant improvements in 
reducing delays, with the fastest 80 percent of clearances taking an 
average of 87 days to complete. As of December 2009, IRTPA’s 
timeliness objective is for each federal agency to process the fastest 
90 percent of initial security clearances within an average of 60 
days, including a period of not longer than 40 days to complete the 
investigative phase and 20 days to complete the adjudicative phase. 
DOD met the 60 day IRTPA timeliness objective for initial personnel 
security clearances, as well as the 20 day objective for the 
timeliness of adjudications, for each of the first, second, and third 
quarters of fiscal year 2010, according to data provided by the 
Performance Accountability Council. GAO’s ongoing work continues to 
examine the timeliness of personnel security clearances in DOD. 

DOD has taken a number of positive steps to integrate quality into its 
investigative and adjudicative processes, including issuing guidance 
and developing tools to measure quality. For example, in November 
2009, the Under Secretary for Defense for Intelligence (USD(I)) issued 
guidance to outline the requirements that adjudicators must adhere to 
when documenting personnel security clearance adjudication rationales. 
Similarly, in March 2010, the USD(I) issued guidance to clarify when 
adjudicators may use incomplete investigative reports as the basis for 
granting clearances. In addition, DOD created two electronic quality 
assessment tools—-the Rapid Assessment of Incomplete Security 
Evaluations (RAISE) and the Review of Adjudication Documentation 
Accuracy and Rationales (RADAR)-—to track the quality of investigative 
and adjudicative documentation. These tools are embedded in DOD’s 
Clearance Adjudication Tracking System (CATS), a system used by all 
non-intelligence DOD Central Adjudication Facilities. Although these 
are positive developments that can contribute to greater visibility 
over the clearance process, these tools have not been fully 
implemented. GAO’s ongoing work continues to examine the 
implementation of these tools and other efforts to ensure that 
momentum is sustained. 

View [hyperlink, http://www.gao.gov/products/GAO-11-185T] or key 
components. For more information, contact Brenda S. Farrell, 202-512-
3604, farrellb@gao.gov. 

[End of section] 

Chairman Akaka, Ranking Member Voinovich, and Members of the 
Subcommittee: 

Thank you for the opportunity to be here today to discuss DOD's 
efforts to improve timeliness and quality of its security clearance 
process. 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 recent unauthorized leak this 
past year of about 500,000 pages of classified documents posted to the 
internet related to the ongoing wars in Afghanistan and Iraq is an 
example of the inherent risks involved when granting an individual a 
security clearance. As you know, there continues to be a high demand 
for security clearances. For example, prior to September 11, 2001, we 
reported that DOD processed about 200,000 security clearances 
annually.[Footnote 1] For fiscal year 2008, we reported that DOD 
approved personnel security clearances for approximately 630,000 
military, civilian, and industrial personnel.[Footnote 2] Government-
wide, the federal government processed nearly 900,000 clearance cases 
annually for the period covering fiscal years 2006 through 2009. DOD 
accounts for the vast majority of all initial security clearances 
making it a formidable challenge to those responsible for deciding who 
should be granted a clearance. 

In light of long-standing concerns regarding delays in processing 
clearances and other issues, Congress has taken a number of actions to 
help ensure the continued focus on improving the personnel security 
clearance processes governmentwide. For example, with the passage of 
the Intelligence Reform and Terrorism Prevention Act (IRTPA) of 2004, 
Congress set objectives and established requirements for improving the 
clearance processes, including requirements related to timeliness, 
reciprocity,[Footnote 3] and an integrated, secure database to house 
clearance information.[Footnote 4] Further, IRTPA required annual 
reports to Congress about personnel security clearance reform, 
including timeliness. In addition, the Intelligence Authorization Act 
for Fiscal Year 2010 stipulates that by February 1 of each year, the 
president will report on, among other things, the number of 
contractors and employees of the U.S. government who hold a security 
clearance, the amount of time it takes the intelligence community to 
make a security clearance determination, and metrics for investigative 
and adjudicative quality.[Footnote 5] Through these annual reports and 
numerous oversight hearings, Congress has provided valuable oversight 
over reform efforts. Specifically, this committee alone has held six 
prior hearings on this issue over the past five years.[Footnote 6] 

In 2005, we designated the Department of Defense's (DOD) personnel 
security clearance program as a high-risk area due to delays in 
processing security clearances.[Footnote 7] We maintained the high-
risk designation in 2007 because of continued delays and additional 
concerns about incomplete clearance documentation in the investigation 
and adjudication phases of the security clearance process.[Footnote 8] 
In 2009, despite significant improvement in reducing delays, we 
continued to designate this program as a high-risk area due to more 
stringent timeliness requirements established by IRTPA that were to 
take effect in December 2009, as well as continuing problems with 
incomplete clearance documentation.[Footnote 9] More specifically, in 
December 2009, IRTPA set new timeliness goals for executive branch 
agencies, requiring decisions on at least 90 percent of initial 
clearance decisions within an average of 60 days and permits the 
executive branch to exclude the slowest 10 percent from the reported 
average.[Footnote 10] With regard to incomplete documentation, we 
noted that building quality throughout DOD's processes was important. 
For example, the lack of quality could increase the risk of 
adjudicators missing patterns of behavior in subsequent clearance 
renewals, undermine reciprocity, increase the risk of unauthorized 
disclosure of classified information, and reduce the assurance that 
appropriate safeguards are in place. 

Executive agencies have also demonstrated a commitment to personnel 
security clearance reform. For example, in 2007, the Director of 
National Intelligence and the Under Secretary of Defense for 
Intelligence (USD(I)) established the Joint Reform Team to coordinate 
governmentwide efforts to achieve timeliness goals established in 
IRTPA and improve the processes related to granting security 
clearances. In 2008, the Joint Reform Team--comprised of entities 
within the Office of Management and Budget (OMB), Office of Personnel 
Management (OPM), Office of the Director of National Intelligence 
(DNI), and USD(I)--developed a plan to transform the clearance process 
and in the following year, developed an Enterprise Information 
Technology Strategy to support the reformed process. In June 2008, the 
president issued Executive Order 13467, establishing a Suitability and 
Security Clearance Performance Accountability Council--commonly known 
as the Performance Accountability Council--as the head of the 
governmentwide governance structure for driving implementation and 
overseeing clearance reform efforts and appointing OMB's Deputy 
Director for Management as the chair. This governance structure was 
put in place, in part, to sustain the momentum of clearance reforms. 
(See Figure 1 for key events related to security clearance reform.) 

Figure 1: Key Events Related to the Security Clearance Reform Effort: 

[Refer to PDF for image: timeline] 

December 17, 2004: 
Intelligence Reform and Terrorist Prevention Act passed. 

January 2005: 
Government Accountability Office places Department of Defense’s 
clearance program on its high-risk list. 

June 27, 2005: 
Executive Order 13881 designates the Office of Management and Budget 
the single entity to ensure centralization, uniformity, and 
reciprocity of security clearance policies. 

November 2005: 
Office of Management and Budget issues a plan for improving the 
security clearance process. 

June 25, 2007: 
The Joint Reform Team is formed to develop a plan for clearance 
reform, including research priorities and an information technology 
strategy, to achieve IRTPA goals. 

April 30, 2008: 
The Joint Reform Team issues a report on reforming the security 
clearance and suitability process. 

June 30, 2008: 
Executive Order 13467 establishes the Performance Accountability 
Council to drive implementation of the reform effort and designated 
the Office of Management and Budget’s Deputy Director for Management 
as Chair. 

December 18, 2008: 
The Joint Reform Team issues a report outlining reform progress and 
further plans. 

March 17, 2009: 
The Joint Reform Team issues an Enterprise Information Technology 
Strategy to support the reformed security and suitability process. 

February 16, 2010: 
The Performance Accountability Council issues a strategic framework to 
articulate the goals of the security and suitability process reform. 

May 31, 2010: 
The Performance Accountability Council develops quality measures a 
that it believes will identify specific quantifiable targets linked to 
goals that are intended to be measured objectively and ultimately 
gauge progress and assess the quality of the personnel security 
clearance process. 

Source: GAO analysis. 

[A] The Quality Measures are proposed measures. 

[End of figure] 

During the past five years, we have conducted numerous reviews that 
have enabled us to gain a historical view of the progress that has 
been made in clearance reform efforts. Specifically, since we first 
placed DOD's personnel security clearance program on our list of high-
risk government programs and operations, we have testified on 
clearance-related issues in 12 prior hearings and issued four reports 
[Footnote 11] with 14 recommendations, including recommendations that 
DOD has implemented to issue guidance that clarifies when adjudicators 
may use incomplete investigative reports as the basis for granting 
clearances and recommendations that OMB has implemented to report on 
the time required to complete all initial clearance applications--not 
just the average of the fastest 90 percent of initial clearances--in 
the executive branch's IRTPA-required annual reports. In response, DOD 
and the Performance Accountability Council have already taken steps to 
implement several of our recommendations aimed at further improving 
DOD's security clearance program. Through our ongoing work, we plan to 
continue to examine the timeliness and quality of personnel security 
clearances in DOD and the extent to which DOD has met our criteria for 
removal of an issue from our high-risk list. This work will help 
determine whether DOD's personnel security clearance program should 
remain on or be removed from our 2011 high-risk list that the 
Comptroller General will announce in January 2011. A list of our 
related GAO products is provided at the end of this statement. 

As requested, my statement today will address DOD's progress in 1) 
reducing the timeliness of initial personnel security clearances and 
2) building quality into personnel security clearance investigation 
and adjudication processes. My statement draws on both our ongoing and 
prior work on the personnel security clearance process. To assess the 
extent to which DOD has made progress in reducing the timeliness of 
initial personnel security clearances, we analyzed IRTPA timeliness 
objectives and reviewed quarterly data provided by the Performance 
Accountability Council's Subcommittee on Performance Measurements and 
Management, chaired by the DNI, which covered the first, second, and 
third quarters of fiscal year 2010. We also interviewed knowledgeable 
DNI officials about the accuracy and completeness of the data they 
provided and determined that these data were sufficiently reliable for 
our purposes. At the time of this testimony, we had not completed our 
independent assessment of the DOD timeliness for fiscal year 2010 
because not all data were available. However, we have begun a 
preliminary analysis of first, second, and third quarter data for 
fiscal year 2010 provided by the Defense Personnel Security Research 
Center. We anticipate completing this analysis after obtaining and 
analyzing DOD's fourth quarter fiscal year 2010 data. To assess the 
extent to which DOD has made progress in building quality into 
personnel security clearance investigation and adjudication processes, 
we interviewed DOD officials who are knowledgeable about quality tools 
and their implementation plans. We also reviewed DOD guidance that 
addresses quality and the implementation of quality tools. Our review 
was performed from October 2010 through November 2010 in accordance 
with generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings 
and conclusions based on our audit objectives. We believe that the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our objectives. 

DOD Has Made Significant Progress in Reducing the Time for Processing 
Initial Personnel Security Clearances for DOD Personnel: 

DOD has made significant progress in reducing delays in personnel 
security clearance decisions and in meeting statutory timeliness 
objectives since we first designated DOD's personnel security 
clearance program as a high-risk area in 2005. In 2007, we found that 
initial clearances for DOD industry personnel took an average of 325 
days to complete.[Footnote 12] With the passage of IRTPA in 2004, 
timeliness requirements were established in law under which executive 
branch agencies were initially required to make decisions on at least 
80 percent of initial clearances within an average of 120 days. We 
found that by 2008, DOD had made significant improvements in reducing 
delays. For example, in examining fiscal year 2008 data, we reported 
that the average of the fastest 80 percent of initial DOD clearances, 
including military, civilians, and industry personnel, took an average 
of 87 days to complete, well below what was required by law[Footnote 
13]. However, despite these improvements, we continued to designate 
this program as a high-risk area due to more stringent timeliness 
objectives that were to take effect in December 2009. IRTPA required 
the Performance Accountability Council to develop a plan under which, 
to the extent practical, each authorized adjudicative agency would be 
required to make a determination on at least 90 percent of all 
applications for a personnel security clearance within an average of 
60 days from the date of receipt of the completed application by an 
authorized investigative agency.[Footnote 14] Although the government 
is required to only report on the average of the fastest 90 percent of 
cases, we previously identified that the absence of comprehensive 
reporting limits full visibility over the timeliness of initial 
clearance decisions. Consistent with GAO's recommendation, the 
government now reports on the remaining 10 percent. 

Our ongoing work has shown that DOD has continued to improve its 
timeliness and DOD reports that it is meeting the new statutory 
timeliness requirements. According to data provided by the Performance 
Accountability Council, DOD initial personnel security clearances met 
the 60 day IRTPA overall timeliness objective and the 20 day objective 
for the timeliness of adjudications for each of the first, second, and 
third quarters of fiscal year 2010, as shown in Table 1.[Footnote 15] 
Over this same period, average timeliness for the fastest 90 percent 
of DOD industry personnel security clearances ranged from 64 days to 
69 days. In addition, DOD reported meeting the IRTPA 40 day timeliness 
objective for investigations in the third quarter of fiscal year 2010. 
However, timeliness data for investigations is a reflection of OPM as 
the investigative service provider for DOD. 

Table 1: Fastest 90 Percent of All DOD Initial Security Clearances for 
First, Second, and Third Quarters of Fiscal Year 2010: 

Department of Defense: 
Investigations (40 days: average days to complete): 
First quarter: 42; 
Second quarter: 45; 
Third quarter: 39; 
Adjudications (20 days: average days to complete): 
First quarter: 15; 
Second quarter: 11; 
Third quarter: 9; 
Combined (60 days: average days to complete): 
First quarter: 57; 
Second quarter: 56; 
Third quarter: 48. 

Department of Defense: Army: 
Investigations (40 days: average days to complete): 
First quarter: 42; 
Second quarter: 45; 
Third quarter: 40; 
Adjudications (20 days: average days to complete): 
First quarter: 10; 
Second quarter: 4; 
Third quarter: 3; 
Combined (60 days: average days to complete): 
First quarter: 52; 
Second quarter: 49; 
Third quarter: 43. 

Department of Defense: Navy: 
Investigations (40 days: average days to complete): 
First quarter: 43; 
Second quarter: 42; 
Third quarter: 38; 
Adjudications (20 days: average days to complete): 
First quarter: 12; 
Second quarter: 18; 
Third quarter: 7; 
Combined (60 days: average days to complete): 
First quarter: 55; 
Second quarter: 60; 
Third quarter: 45. 

Department of Defense: Air Force: 
Investigations (40 days: average days to complete): 
First quarter: 40; 
Second quarter: 41; 
Third quarter: 39; 
Adjudications (20 days: average days to complete): 
First quarter: 28; 
Second quarter: 12; 
Third quarter: 9; 
Combined (60 days: average days to complete): 
First quarter: 68; 
Second quarter: 53; 
Third quarter: 48. 

Department of Defense: Industry[A]: 
Investigations (40 days: average days to complete): 
First quarter: 44; 
Second quarter: 49; 
Third quarter: 41; 
Adjudications (20 days: average days to complete): 
First quarter: 20; 
Second quarter: 20; 
Third quarter: 26; 
Combined (60 days: average days to complete): 
First quarter: 64; 
Second quarter: 69; 
Third quarter: 67. 

Department of Defense: DOD other[B]: 
Investigations (40 days: average days to complete): 
First quarter: 89; 
Second quarter: 51; 
Third quarter: 48; 
Adjudications (20 days: average days to complete): 
First quarter: 42; 
Second quarter: 29; 
Third quarter: 21; 
Combined (60 days: average days to complete): 
First quarter: 131; 
Second quarter: 80; 
Third quarter: 69. 

Source: Performance Accountability Council data. 

[A] DOD's Defense Industrial Security Clearance Office adjudicates 
clearances for industrial personnel. When the Defense Industrial 
Security Clearance Office identifies issues with these cases that may 
potentially affect the adjudicative decision, they submit the cases to 
the Defense Office of Hearings and Appeals. The time it takes the 
Defense Industrial Security Clearance Office to arrive at the initial 
decision is included in DOD timeliness. However, timeliness 
information is not reported for cases sent to the Defense Office of 
Hearings and Appeals. 

[B"] DOD other" includes 1) all secret and confidential clearances and 
initial top secret clearances adjudicated by the DOD Central 
Adjudication Facilities for the Joint Chiefs of Staff and the 
Washington Headquarters Services and 2) the initial Sensitive 
Compartmented Information clearance cases adjudicated on their behalf 
by elements of the intelligence community, such as the Defense 
Intelligence Agency. 

[End of table] 

Although DOD has made significant progress in reducing delays in 
making personnel security clearance decisions, it is important that 
DOD sustain this progress. Reducing delays in the security clearance 
process will enable DOD to reduce risks to national security, expedite 
the start of classified work, hire the best-qualified workers, and 
decrease the government's cost of national security-related contracts. 

Positive Steps Have Been Taken to Address Quality and Enhance 
Visibility Over the Security Clearance Process: 

We are also encouraged by a number of recent developments that are 
intended to enhance visibility over the quality of the security 
clearance process. In our prior work, we have stated that timeliness 
alone does not provide a complete picture of the clearance process and 
we emphasized the need for attention to quality. However, we found an 
uneven attention to quality within DOD's process; specifically, we 
found missing documentation in reports prepared by OPM that DOD 
adjudicators had used to make clearance decisions. In May 2009, for 
example, we estimated that 87 percent of OPM investigative reports 
provided to DOD at three Central Adjudication Facilities in July 2008 
were missing required documentation.[Footnote 16] Because neither OPM 
nor DOD measured the completeness of their investigative reports or 
adjudicative files, we reported that both agencies were limited in 
their ability to explain the extent to which, or the reasons why, some 
documents were incomplete. Incomplete documentation may increase the 
time needed to complete the clearance process, increase the overall 
costs of the process, and reduce the assurance that appropriate 
safeguards are in place to prevent DOD from granting clearances to 
untrustworthy individuals. We emphasized that building quality 
throughout DOD's process could promote positive outcomes, such as 
facilitating reciprocity with other agencies. 

DOD has taken a number of positive steps to integrate quality into its 
investigative and adjudicative processes and demonstrated the 
commitment of senior leadership to reforming the personnel security 
process within DOD. For example, according to DOD officials, DOD 
recently initiated the creation of a Performance Accountability 
Directorate within USD(I)'s Directorate of Security to provide 
oversight and accountability for the DOD Central Adjudication 
Facilities that process DOD adjudicative decisions. Most importantly, 
DOD has also issued guidance and developed tools to measure quality. 
For example: 

Guidance. DOD has taken steps to issue guidance on adjudication 
standards. On November 8, 2009, the USD(I) issued guidance on 
adjudication standards that outline the minimum documentation 
requirements adjudicators must adhere to when documenting personnel 
security clearance adjudication rationales in the Joint Adjudication 
Management System.[Footnote 17] These standards are for cases with 
significant derogatory information and for Single Scope Background 
Investigations[Footnote 18] that are missing standard investigative 
scope items but were still adjudicated. In response to our 
recommendation, the USD(I) issued additional guidance on March 10, 
2010 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 missing 
or incomplete scope items. 

Tools. DOD has taken steps to measure the frequency with which 
documentation for investigations and adjudications meets federal 
standards. DOD developed two tracking tools--the Rapid Assessment of 
Incomplete Security Evaluations (RAISE) and the Review of Adjudication 
Documentation Accuracy and Rationales (RADAR)--to assess the quality 
of investigative and adjudication documentation. These tracking tools 
are embedded capabilities in DOD's Clearance Adjudication Tracking 
System (CATS), which is used by all non-intelligence DOD Central 
Adjudication Facilities. Although these are positive steps, it is too 
early to assess the effectiveness of these tools as they have not yet 
been fully deployed. 

* The RAISE tracking tool will document the instances of missing case 
information or unresolved case issues for records of investigation 
provided by OPM.[Footnote 19] In July 2010, DOD issued guidance 
requiring that each DOD Central Adjudication Facility that utilizes 
the Clearance Adjudication Tracking System use the RAISE tracking tool 
on all incomplete national security investigations and on random 
samples of other clearance cases accounting for 7 percent of their 
respective Single Scope Background Investigations and 14 percent of 
both their Periodic Reinvestigations and National Agency Check with 
Local Agency Check and Credit Check investigations. The results are to 
be reported to the DNI who, as Security Executive Agent of the 
Performance Accountability Council, will arbitrate disagreements 
between OPM and DOD and clarify policy questions. DOD deployed the 
RAISE tracking tool to four Central Adjudication Facilities between 
July and October 2010 and plans to complete deployment to the 
remaining Central Adjudication Facilities by the beginning of calendar 
year 2011. 

* The RADAR tracking tool will enable DOD to independently evaluate 
the quality of adjudicative decisions against the adjudicative 
standards. The USD(I) has directed DOD Central Adjudication Facilities 
to provide adjudication case records to the Defense Personnel Research 
Center for analysis. The USD(I) plans to use results of the RADAR 
tracking tool 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 the RADAR tracking tool and 
has begun its implementation for the Army, Defense Industrial Security 
Clearance Office, and Navy Central Adjudication Facilities in 
September 2010. Further, implementation is scheduled for the Air Force 
and Washington Headquarters Services by November 2010. 

Beyond these steps, DOD has participated in the development and 
tracking of quality metrics through the Performance Accountability 
Council. On March 17, 2010, the leaders of the reform effort--the OMB, 
OPM, DNI, and DOD--along with GAO, briefed this Subcommittee's 
chairman and ranking member on the status of security clearance reform 
efforts. Subsequent to this briefing, this Subcommittee requested that 
the Joint Reform Team and GAO engage in an effort to develop metrics 
to measure the quality of security clearance investigations and 
adjudications in order to address GAO's concerns about quality. In May 
2010, the leaders of the reform effort provided this Subcommittee with 
15 metrics assessing the timeliness and quality of investigations, 
adjudications, reciprocity, and automation. According to Joint Reform 
Team officials, these metrics were communicated to executive agencies 
in June 2010. Given the role of the executive branch and the need for 
GAO to remain independent in carrying out its auditing 
responsibilities, decisions related to performance measures and their 
effective implementation are fundamentally an executive branch 
management responsibility. However, we are encouraged by the Joint 
Reform Team's collaborative efforts to develop these quality measures. 
We have previously reported that successful performance measures 
should meet nine criteria.[Footnote 20] For example, successful 
measures should clearly link to agency goals, have measurable targets, 
and be reasonably free from bias. GAO has been examining the 
Performance Accountability Council metrics and our preliminary 
observations show that many of the quality metrics appear to address 
attributes of a successful performance measure, such as being 
objective, quantifiable, and are linked to reform effort goals. We 
view the quality metrics as a positive step towards identifying 
specific quantifiable targets linked to goals that can be measured 
objectively and used by leaders and others to gauge progress and 
assess the quality of the personnel security clearance process. 
Although these are positive developments that can contribute to 
greater visibility over the clearance process, these measures have not 
yet been fully implemented and we are continuing to examine these 
efforts as part of our ongoing work. 

In conclusion, Mr. Chairman, we are strongly encouraged by the 
progress that the Performance Accountability Council, and in 
particular, DOD, has made over the last few years to implement 
recommendations, reduce overall timeliness, and take steps to 
integrate quality into its processes. As I have already noted, based 
on Performance Accountability Council data, DOD has reported that it 
is meeting IRTPA timeliness requirements for the first three quarters 
of fiscal year 2010, which represents significant and noteworthy 
progress. Moreover, 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. 
Their continued oversight and stewardship of the reform efforts is the 
cornerstone to sustaining momentum and making future progress. 
Although DOD has taken steps to develop and implement quality 
assessment tools, these tools have not yet been fully implemented. 
Therefore, it is important that management focus is sustained to 
ensure that these efforts are implemented and continuously evaluated. 
We are continuing to track timeliness and monitor the implementation 
and results of DOD's quality assessment tools. This work will help 
inform the Comptroller General's high-risk update decision in January 
2011. 

Mr. Chairman, this concludes my prepared statement. I would be pleased 
to respond at this time to any questions that you or members of the 
Subcommittee may have at this time. 

GAO Contact and Staff Acknowledgments: 

For further information regarding this testimony, 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 statement. Individuals who made key contributions to this 
testimony are Liz McNally, Assistant Director; James Ashley; Joseph M. 
Capuano; Sara Cradic; Cindy Gilbert; Linda Keefer; James Krustapentus; 
Greg Marchand; Richard Powelson; and Jillena Roberts. 

[End of section] 

Related GAO Products: 

Privacy: OPM Should Better Monitor Implementation of Privacy-Related 
Policies and Procedures for Background Investigations, [hyperlink, 
http://www.gao.gov/products/GAO-10-849]. Washington, D.C.: September 
7, 2010. 

Personnel Security Clearances: An Outcome-Focused Strategy and 
Comprehensive Reporting of Timeliness and Quality Would Provide 
Greater Visibility over the Clearance Process. [hyperlink, 
http://www.gao.gov/products/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. [hyperlink, http://www.gao.gov/products/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. [hyperlink, 
http://www.gao.gov/products/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. [hyperlink, 
http://www.gao.gov/products/GAO-09-400]. Washington, D.C.: May 19, 
2009. 

High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-09-271]. Washington, D.C.: January 22, 
2009. 

DOD Personnel Clearances: Preliminary Observations about Timeliness 
and Quality. [hyperlink, http://www.gao.gov/products/GAO-09-261R]. 
Washington, D.C.: December 19, 2008. 

Personnel Security Clearances: Preliminary Observations on Joint 
Reform Efforts to Improve the Governmentwide Clearance Eligibility 
Process. [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. 

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.: February 
12, 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: 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. 

High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-07-310]. Washington, D.C.: January 
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. 

DOD Personnel Clearances: Questions and Answers for the Record 
Following the Second in a Series of Hearings on Fixing the Security 
Clearance Process. [hyperlink, 
http://www.gao.gov/products/GAO-06-693R]. Washington, D.C.: June 14, 
2006. 

DOD Personnel Clearances: New Concerns Slow Processing of Clearances 
for Industry Personnel. [hyperlink, 
http://www.gao.gov/products/GAO-06-748T. Washington, D.C.: May 17, 
2006. 

DOD Personnel Clearances: Funding Challenges and Other Impediments 
Slow Clearances for Industry Personnel. [hyperlink, 
http://www.gao.gov/products/GAO-06-747T]. Washington, D.C.: May 17, 
2006. 

Questions for the Record Related to DOD's Personnel Security Clearance 
Program and the Government Plan for Improving the Clearance Process. 
[hyperlink, http://www.gao.gov/products/GAO-06-323R]. Washington, 
D.C.: January 17, 2006. 

DOD Personnel Clearances: Government Plan Addresses Some Long-standing 
Problems with DOD's Program, But Concerns Remain. [hyperlink, 
http://www.gao.gov/products/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 
Designation. [hyperlink, http://www.gao.gov/products/GAO-05-842T]. 
Washington, D.C.: June 28, 2005. 

High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-05-207]. Washington, D.C.: January 
2005. 

[End of section] 

Footnotes: 

[1] GAO, DOD Personnel: More Consistency Needed in Determining 
Eligibility for Top Secret Security Clearances, [hyperlink, 
http://www.gao.gov/products/GAO-01-465] (Washington, D.C.: Apr. 18, 
2001). 

[2] GAO, DOD Personnel Clearances: Preliminary Observations about 
Timeliness and Quality, [hyperlink, 
http://www.gao.gov/products/GAO-09-261R], (Washington, D.C.: Dec. 19, 
2008) 

[3] For the purposes of this testimony, we define reciprocity as an 
agency's acceptance of a background investigation or clearance 
determination completed by any authorized investigative or 
adjudicative agency. 

[4] Pub. L. No. 108-458, § 3001 (2004) (codified at 50 U.S.C. § 435b). 
While IRTPA was a far-reaching act with many broad implications, our 
references to it throughout this report pertain solely to section 
3001, unless otherwise specified. 

[5] Pub. L. No. 111-259, § 367 (2010). 

[6] GAO, DOD Personnel Clearances: Some Progress Has Been Made but 
Hurdles Remain to Overcome the Challenges That Led to GAO's High-Risk 
Designation, [hyperlink, http://www.gao.gov/products/GAO-05-842T] 
(Washington, D.C.: June 28, 2005); GAO, DOD Personnel Clearances: 
Government Plan Addresses Some Long-standing Problems with DOD's 
Program, But Concerns Remain, [hyperlink, 
http://www.gao.gov/products/GAO-06-233T] (Washington, D.C.: Nov. 9, 
2005); GAO, DOD Personnel Clearances: Funding Challenges and Other 
Impediments Slow Clearances for Industry Personnel, [hyperlink, 
http://www.gao.gov/products/GAO-06-747T] (Washington, D.C.: May 17, 
2006); GAO, 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); GAO, 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); and GAO, Personnel Security Clearances: Progress Has Been Made 
to Reduce Delays But Further Actions Are Needed to Enhance Quality and 
Sustain Reform Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-09-684T] (Washington, D.C.: Sep. 15, 
2009). The Subcommittee on Intelligence Community Management, House 
Permanent Select Committee on Intelligence; the Subcommittee on 
Readiness, House Committee on Armed Services; and the Subcommittee on 
Government Management, Organization and Procurement, House Committee 
on Oversight and Government Reform have also held hearings on this 
issue. 

[7] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-05-207] (Washington, D.C.: January 
2005). 

[8] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-07-310] (Washington, D.C.: January 
2007). 

[9] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-09-271] (Washington, D.C. January 
2009). 

[10] This 60 day period is to include periods of not more than 40 days 
to complete the investigative phase and 20 days to complete the 
adjudicative phase from the date of receipt of the completed 
application by an authorized investigative agency. 

[11] GAO, Personnel Security Clearances: An Outcome-Focused Strategy 
Is Needed to Guide Implementation of the Reformed Clearance Process, 
[hyperlink, http://www.gao.gov/products/GAO-09-488] (Washington, D.C.: 
May 19, 2009); GAO, DOD Personnel Clearances: Comprehensive Timeliness 
Reporting, Complete Clearance Documentation, and Quality Measures Are 
Needed to Further Improve the Clearance Process, [hyperlink, 
http://www.gao.gov/products/GAO-09-400] (Washington, D.C.: May 19, 
2009); GAO, DOD Personnel Clearances: Improved Annual Reporting Would 
Enable More Informed Congressional Oversight, [hyperlink, 
http://www.gao.gov/products/GAO-08-350] (Washington, D.C.: Feb. 13, 
2008); and GAO, 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.: Sep. 28, 
2006). 

[12] [hyperlink, http://www.gao.gov/products/GAO-09-271]. 

[13] [hyperlink, http://www.gao.gov/products/GAO-09-400]. 

[14] Pub. L. No. 108-458, § 3001 (2004) (codified at 50 U.S.C. § 
435b). According to IRTPA, this period shall include a period of not 
longer than 40 days to complete the investigative phase of the 
clearance review and a period of not longer than 20 days to complete 
the adjudicative phase of the clearance review. These measures apply 
to initial personnel security clearances. 

[15] The annual report to Congress contained self reported agency data 
that was provided to the PAC Subcommittee on Performance Measurements 
and Management. This data excludes the elements of the intelligence 
community under DOD, such as the Defense Intelligence Agency, National 
Reconnaissance Office, National Geospatial-Intelligence Agency, and 
National Security Agency, but does include the intelligence components 
of the military departments. According to DOD officials, DOD's system 
for tracking and reporting security clearance case information does 
not differentiate between initial secret/confidential clearances and 
renewal secret/confidential clearances. Therefore, the Performance 
Accountability Council timeliness reports on initial clearances 
include DOD secret/confidential renewal cases, as well as initial 
secret, confidential, top secret, and sensitive compartmented 
information clearances. A prior GAO review and OPM officials' 
estimates of DOD clearance timeliness in fiscal year 2009 indicated 
that confidential and secret level clearances, whether initial or 
renewal, generally took the same amount of time to investigate. 
Furthermore, the Defense Personnel Security Research Center--a DOD 
entity dedicated to improving the effectiveness, efficiency, and 
fairness of the DOD personnel security system--issued a working paper 
that showed that average adjudication timeliness did not substantially 
differ between initial and renewal secret clearance cases for DOD 
using first, second, and third quarter data for fiscal year 2008. 

[16] [hyperlink, http://www.gao.gov/products/GAO-09-400]. 

[17] The Joint Adjudication Management System is a subsystem of the 
Joint Personnel Adjudication System and provides the capability for 
DOD adjudicators to record eligibility decisions and potentially 
disqualifying information. 

[18] Single Scope Background Investigations are used to support 
initial top secret with Sensitive Compartmented Information clearance 
adjudicative decisions. 

[19] In addition to DOD's tools to assess the quality of 
investigations and adjudications, the broader reform effort also has 
two quality tools sponsored by OPM. First, the Quality Assessment 
Tool, deployed by OPM in March 2010, is designed to track OPM 
investigations provided to adjudicators that were deemed quality 
deficient by the adjudicators. Second, the Quality Hotline is designed 
for adjudicators in agencies for which OPM is the investigative 
service provider to report deficient investigations. However, 
according to DOD officials we spoke with, DOD asked the DOD Central 
Adjudication Facilities to not use the OPM quality assessment tools 
because of the lack of oversight. According to these officials, these 
tools are primarily for suitability, not national security. 

[20] GAO, Tax Administration: IRS Needs to Further Refine Its Tax 
Filing Season Performance Measures, [hyperlink, 
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22, 
2002). 

[End of section] 

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