Though representing separate organizations, the two CI offices share resources, funds, andpersonnel for some programs. (11) 
As part of the restructuring, Congress proposed creating dual CI offices in DOE and NNSA.Within DOE, the already-existing Office of Counterintelligence (OCI) was codified and maderesponsible for developing CI policy for both DOE and NNSA; but, was only authorized to implement that policy at non-NNSA facilities. The NNSAAdministrator would report to the Energy Secretary. Supporters argue that a separate, dedicated CI office within NNSA is necessary ifcounterintelligence is to receive the focus it warrants. Second, is the current partially bifurcated CI managementstructure within DOE and NNSA the most effective approach to CI management? (20) The PFIAB, in 1999 recommended the establishment of a semi-autonomous agency within DOE, with its own coherentCI structure. (25) 
Former DOE Secretary Spencer Abraham, after completing his own review of the bifurcatedCI structure, concluded in 2003 that the structure was "not optimal"and proposed to Congress thatthe Department's two CI programs be consolidated under DOE's control, and that the combinedoffice report directly to the Energy Secretary. (29) If Congress, however,ultimately decides to modify the structure, a number of organizational approaches have beenproposed. Alternative One: Maintain the Status Quo

DOE's Office of Counterintelligence would continue to be responsible for developing CIpolicy across DOE (including the NNSA) but implementing that policy only at non-NNSA facilities. (NNSA/ODNCI) would continue to implement CI policy at NNSA facilities. Proponents suggest that this approach would establish clearer lines of authority for CI within DOEand NNSA, which would improve communication and coordination. Opponents counter that suchan arrangement would produce chaos at the field level and could lead to future problems ofredundancy, coordination, communications, and relations with law enforcement. Opponents counter that this approach would leave in place two CI offices, one withpolicymaking responsibilities and one with operational responsibilities, thereby contributing tocontinuing confusion as to roles and mission. Alternative Four: Consolidate All CI Within DOE

The final approach consolidates the two CI programs, either under the control of the EnergySecretary, or under the control of the NNSA administrator. Proponents of DOE consolidation assertthat the importance of CI argues for a consolidated effort controlled by the Energy Secretary. (33) 
Opponents counter that consolidating CI under DOE control would be inconsistent withCongress' intent to maximize NNSA autonomy in all areas, and particularly with regard to CI,because of DOE's perceived deeply rooted anti-security culture.
Troubled by reported lapses in security and counterintelligence (CI) at the Department ofEnergy (DOE), the Congress in 1999 established a semi-autonomous agency -- the National NuclearSecurity Administration (NNSA) -- to oversee DOE's national security-related programs ( P.L.106-65 ). Within NNSA, Congress created the Office of Defense Nuclear Counterintelligence to implement CI policy at NNSA facilities. DOE retained a separate Office of Counterintelligence,which develops CI policy for DOE and NNSA, but, implements it only at non-NNSA facilities. Though representing separate organizations, the two CI offices share resources and personnel forsome programs. Although DOE has taken steps to strengthen CI practices, some observers havequestioned whether the Department's bifurcated CI structure is the most effective in counteringcontinuing efforts by foreign intelligence services, friendly and hostile, to target DOE and NNSAfacilities.
Several organizational approaches have been discussed, including the following.
One approach is to maintain the status quo. Proponents suggest that the current structureis necessary if CI is to receive the attention it warrants. Opponents counter that dual offices lead toinefficiencies that could undermine CI effectiveness.
Under a second approach, DOE and NNSA CI programs could be completely separated. Proponents suggest that this approach would establish clearer lines of authority. Opponents counterthat this arrangement would produce chaos at the field level and lead to coordination andcommunication problems.
A third approach would be to give NNSA authority to implement all CI programming, whilepreserving for DOE all CI policymaking responsibility. Proponents suggest that doing so wouldresult in integrated and coordinated CI operational activity. Opponents counter that this approachstill would leave in place two separate CI offices and lead to continuing confusion over roles andmission.
Finally, Congress could consolidate the two CI programs, either under the direct control ofthe Energy Secretary, or under the supervision of the NNSA administrator. Proponents of DOEcontrol assert that the importance of CI argues for a consolidated office that answers directly to theDOE Secretary. Opponents contend consolidation within DOE would contravene Congress's intentto maximize NNSA autonomy in all areas, including CI, because of DOE's perceived deeply rootedanti-security culture. They recommend that all CI programs be consolidated, but under the NNSAAdministrator rather than the Energy Secretary.
Former DOE Secretary Spencer Abraham proposed consolidating the two CI programs intoa single office reporting directly to the Energy Secretary. Congress, however, continues to supportthe bifurcated program. Energy Secretary Samuel W. Bodman is reviewing various legislativeproposals, including one that would consolidate the two CI programs under DOE control. Thisreport will be updated as warranted.