	Background

Although our high-risk designation covers only DOD’s program, our  reports have also documented clearance-related problems affecting other  agencies. For example, our October 2007 report on state and local  information fusion centers cited two clearance-related challenges: (1) the  length of time needed for state and local officials to receive clearances  from the Federal Bureau of Investigation (FBI) and the Department of  Homeland Security (DHS) and (2) the reluctance of some federal  agencies—particularly DHS and FBI—to accept clearances issued by other  agencies (i.e., clearance reciprocity). Four Key Factors Should Be Considered in Efforts to Reform Security Clearance Processes

I will address the need for consideration of four key factors in my  testimony: (1) a strong requirements-determination process, (2) quality  emphasis in all clearance processes, (3) additional metrics to provide a  fuller picture of clearance processes, and (4) long-term funding  requirements of security clearance reform. We are not suggesting that the  numbers and levels of clearances are or are not appropriate—only that any  unnecessary requirements in this initial phase use government resources  that can be utilized for other purposes such as building additional quality  into other clearance processes or decreasing delays in clearance  processing. Since (1) the average  investigative report for a top secret clearance takes about 10 times as  many investigative staff hours as the average investigative report for a  secret clearance and (2) the top secret clearance must be renewed twice  as often as the secret, the investigative workload increases about 20-fold. When OMB issued its February 2007 Report of the Security Clearance  Oversight Group Consistent with Title III of the Intelligence Reform and  Terrorism Prevention Act of 2004, it documented quality with a single  metric. GAO has long reported that it is problematic to equate the quality of  investigations with the percentage of investigations that are returned by  requesting agencies due to incomplete case files. Incomplete investigations and adjudications  undermine the government’s efforts to move toward greater clearance  reciprocity. Without full documentation of  investigative actions, information obtained, and adjudicative decisions,  agencies could continue to require duplicative investigations and  adjudications. Government Clearance Metrics Emphasize Timeliness Measurement, but Additional Metrics Could Provide a Fuller Picture of Clearance Processes

Much of the recent quantitative information provided on clearances has  dealt with how much time it takes for the end-to-end processing of  clearances (and related measures such as the numbers of various types of  investigative and adjudicative reports generated); however, there is less  quantitative information on other aspects of the clearance process. Among other things, IRTPA established  specific timeliness guidelines to be phased in over 5 years. Including these and other types of metrics in regular monitoring of  clearance processes could add value in current and future reform efforts  as well as supply better information for greater congressional oversight. Long-Term Funding Requirements Information Could Enable More Informed Congressional Oversight of Security Clearance Reform

The joint Security Clearance Process Reform team may also want to  consider providing Congress with the long-term funding requirements to  implement changes to security clearance processes enabling more  informed congressional oversight. Specifically,  DOD’s August 2007 congressionally mandated report on clearances for  industry personnel provided less than 2 years of data on funding  requirements. However, the report did not include information on (1) the  funding requirements for fiscal year 2009 and beyond even though the  survey used to develop the funding requirements asked contractors about  their clearance needs through 2010 and (2) the tens of millions of dollars  that the Defense Security Service Director testified before Congress in  May 2007 were necessary to maintain the infrastructure supporting the  industry personnel security clearance program. As noted in our February 2008 report, the inclusion of less than 2 future  years of budgeting information in the DOD report limits Congress’s ability  to carry out its oversight and appropriations functions pertaining to  industry personnel security clearances. GAO’s experience in evaluating DOD’s and governmentwide  clearance plans and programs as well as its experience monitoring large- scale, complex acquisition programs could help Congress in its oversight,  insight, and foresight regarding security clearance reform efforts. Questions for the Record Related to DOD’s Personnel Security Clearance  Program and the Government Plan for Improving the Clearance Process.
Why GAO Did This Study

In 2004, Congress passed the Intelligence Reform and Terrorism Prevention Act to reform security clearance processes. Much of GAO's experience in evaluating personnel security clearance processes over the decades has consisted of examining the Department of Defense's (DOD) program, which maintains about 2.5 million clearances on servicemembers, DOD civilian employees, legislative branch employees, and industry personnel working for DOD and 23 other federal agencies. Long-standing delays in processing applications--and other problems in DOD's clearance program--led GAO to designate it a high-risk area in 2005. GAO also has documented clearance-related problems in other agencies. For this hearing, GAO was asked to identify key factors that could be applied in personnel security clearance reform efforts. To identify key factors, GAO drew upon its past reports and institutional knowledge. For those reports, GAO reviewed laws, executive orders, policies, reports, and other documentation related to the security clearance process; examined samples of cases of personnel granted top secret eligibility; compared documentation in those sampled cases against federal standards; and interviewed a range of cognizant government officials.

What GAO Found

Current and future efforts to reform personnel security clearance processes should consider, among other things, the following four key factors: determining whether clearances are required for positions, incorporating quality control steps throughout the clearance processes, establishing metrics for assessing all aspects of clearance processes, and providing Congress with the long-term funding requirements of security clearance reform. Requesting a clearance for a position in which it will not be needed, or in which a lower- level clearance would be sufficient, will increase both costs and investigative workload unnecessarily. For example, changing the clearance needed for a position from a secret to top secret increases the investigative workload for that position about 20-fold and uses 10 times as many investigative staff hours. Emphasis on quality in clearance processes could promote positive outcomes, including more reciprocity among agencies in accepting each others' clearances. Building quality throughout clearance processes is important, but government agencies have paid little attention to quality, despite GAO's repeated suggestions to place more emphasis on quality. Even though GAO identified the government's primary metric for assessing quality--the percentage of investigative reports returned for insufficiency during the adjudicative phase--as inadequate by itself in 1999, the Office of Management and Budget and the Office of Personnel Management continue to use that metric. Concerns about the quality of investigative and adjudicative work underlie the continued reluctance of agencies to accept clearances issued by other agencies; as a result, government resources are used to conduct duplicative investigations and adjudications. Many efforts to monitor clearance processes emphasize measuring timeliness, but additional metrics could provide a fuller picture of clearance processes. The emphasis on timeliness is due in part to recent legislation that provides specific guidelines regarding the speed with which clearances should be completed and requires annual reporting of that information to Congress. GAO has highlighted a variety of metrics in its reports (e.g., completeness of investigative and adjudicative reports, staff's and customers' perceptions of the processes, and the adequacy of internal controls), all of which could add value in monitoring clearance processes and provide better information to allow improved oversight by Congress and the Executive Branch. Another factor to consider in reform efforts is providing Congress with the long-term funding requirements to implement changes to security clearance processes. DOD's August 2007 congressionally mandated report on industry clearances identified its immediate funding needs but did not include information on the funding requirements for fiscal year 2009 and beyond. The inclusion of less than 2 future years of budgeting data in the DOD report limits Congress's ability to carry out its long-term oversight and appropriations functions pertaining to industry personnel security clearances.