	The Personnel Security Clearance Process

Multiple executive-branch agencies are responsible for different phases of  the federal government’s personnel security clearance process. As such, the DNI is responsible for developing  policies and procedures to help ensure the effective, efficient, and timely  completion of background investigations and adjudications relating to  determinations of eligibility for access to classified information and  eligibility to hold a sensitive position. OPM  provides the resulting investigative reports to the requesting agencies for  their internal adjudicators, who use the information along with the federal  adjudicative guidelines to determine whether an applicant is eligible for a  personnel security clearance. In a 2008 memorandum, the President called  for a reform of the security clearance and suitability determination  processes and subsequently issued Executive Order 13467, which in  addition to designating the DNI as the Security Executive Agent, also  designated the Director of OPM as the Suitability Executive Agent. Steps in the Personnel Security Clearance Process

To help ensure the trustworthiness and reliability of personnel in positions  with access to classified information, executive branch agencies rely on a  personnel security clearance process that includes multiple phases:  requirements determination, application, investigation, adjudication,  appeals (if applicable, where a clearance has been denied), and  reinvestigation (where applicable, for renewal or upgrade of an existing  clearance). Reinvestigation Phase

Once an individual has obtained a personnel security clearance and as  long as he or she remains in a position that requires access to classified  national security information, that individual is reinvestigated periodically  at intervals that depend on the level of security clearance. Actions Needed to Ensure Quality of Clearance Investigations and Adjudications

Executive branch agencies do not consistently assess quality throughout  the personnel security clearance process, in part because they have not  fully developed and implemented metrics to measure quality in key  aspects of the process. We have emphasized—since the late 1990s—the  need to build and monitor quality throughout the personnel security  clearance process to promote oversight and positive outcomes such as  maximizing the likelihood that individuals who are security risks will be  scrutinized more closely. For example, in May 2009, we reported that, with respect to DOD initial  top secret clearances adjudicated in July 2008, documentation was  incomplete for most OPM investigative reports. We independently  estimated that 87 percent of about 3,500 investigative reports that DOD  adjudicators used to make clearance decision were missing at least one  type of documentation required by federal investigative standards. The  type of documentation most often missing from investigative reports was  verification of all of the applicant’s employment followed by information  from the required number of social references for the applicant and  investigative reports did not contain a required personal subject interview. Extent of Clearance Reciprocity Is Not Measured

Although executive branch agency officials have stated that reciprocity is  regularly granted as it is an opportunity to save time as well as reduce  costs and investigative workloads, we reported in 2010 that agencies do  not consistently and comprehensively track the extent to which reciprocity  is granted government-wide. In addition to establishing objectives for  timeliness, the Intelligence Reform and Terrorism Prevention Act of 2004  established requirements for reciprocity, which is an agency’s acceptance  of a background investigation or clearance determination completed by  any authorized investigative or adjudicative executive branch agency,  subject to certain exceptions such as completing additional requirements  like polygraph testing. The guidance  requires, except in limited circumstances, that all Intelligence Community  elements “accept all in-scope security clearance or access  determinations.” Additionally, Office of Management and Budget guidance  requires agencies to honor a clearance when (1) the prior clearance was  not granted on an interim or temporary basis; (2) the prior clearance  investigation is current and in-scope; (3) there is no new adverse  information already in the possession of the gaining agency; and (4) there  are no conditions, deviations, waivers, or unsatisfied additional  requirements (such as polygraphs) if the individual is being considered for  access to highly sensitive programs. Because of these issues identified by agency officials as hindrances to  reciprocity and because the extent of reciprocity was unknown, we  recommended in 2010 that the Deputy Director of Management, Office of  Management and Budget, in the capacity as Chair of the Performance  Accountability Council, should develop comprehensive metrics to track  reciprocity and then report the findings from the expanded tracking to  Congress. In conclusion, to avoid the risk of damaging, unauthorized disclosures of  classified information, oversight of the reform efforts to measure and  improve the quality of the security clearance process is imperative. Assurances that all clearances are of a high quality may  further encourage reciprocity of investigation and adjudications. DOD Personnel Clearances: Preliminary Observations on DOD’s  Progress on Addressing Timeliness and Quality Issues.
Why GAO Did This Study

Recently the DNI reported that more than 5.1 million federal government and contractor employees held or were eligible to hold a security clearance. GAO has reported that the federal government spent over $1 billion to conduct background investigations (in support of security clearances and suitability determinations for federal employment) in fiscal year 2011. A high quality process is essential to minimize the risks of unauthorized disclosures of classified information and to help ensure that information about individuals with criminal activity or other questionable behavior is identified and assessed as part of the process for granting or retaining clearances.
This statement addresses (1) a general overview of the security clearance process; (2) what is known about the quality of investigations and adjudications, which are the determinations made by executive branch agency officials to grant or reject clearance requests based on investigations; and (3) the extent of reciprocity, which is the decision of agencies to honor clearances previously granted by other agencies. This statement is based on GAO work issued from 2008 to 2013 on DOD's personnel security clearance program and government-wide suitability and security clearance reform efforts. As part of that work, GAO (1) reviewed relevant statutes, federal guidance, and processes, (2) examined agency data on the timeliness and quality of investigations and adjudications, (3) assessed reform efforts, and (4) reviewed a sample of case files for DOD personnel.

What GAO Found

Several agencies have key roles and responsibilities in the multi-phased personnel security clearance process, including the Director of National Intelligence (DNI) who, as the Security Executive Agent, is responsible for developing policies and procedures related to security clearance investigations and adjudications, among other things. The Deputy Director for Management at the Office of Management and Budget chairs the Performance Accountability Council that oversees reform efforts to enhance the personnel security process. The security process includes: the determination of whether a position requires a clearance, application submission, investigation, and adjudication. Specifically, agency officials must first determine whether a federal civilian position requires access to classified information. After an individual has been selected for a position that requires a personnel security clearance and the individual submits an application for a clearance, investigators—often contractors—from the Office of Personnel Management (OPM) conduct background investigations for most executive branch agencies. Adjudicators from requesting agencies use the information from these investigations and federal adjudicative guidelines to determine whether an applicant is eligible for a clearance. Further, individuals are subject to reinvestigations at intervals based on the level of security clearance.
Executive branch agencies do not consistently assess quality throughout the personnel security clearance process, in part because they have not fully developed and implemented metrics to measure quality in key aspects of the process. For more than a decade, GAO has emphasized the need to build and monitor quality throughout the clearance process to promote oversight and positive outcomes such as maximizing the likelihood that individuals who are security risks will be scrutinized more closely. GAO reported in 2009 that, with respect to initial top secret clearances adjudicated in July 2008 for the Department of Defense (DOD), documentation was incomplete for most of OPM's investigative reports. GAO independently estimated that 87 percent of about 3,500 investigative reports that DOD adjudicators used to make clearance eligibility decisions were missing some required documentation, such as the verification of all of the applicant's employment, the required number of social references for the applicant, and complete security forms. In May 2009, GAO recommended that OPM measure the frequency with which its investigative reports met federal investigative standards to improve the completeness—that is, quality—of investigation documentation. In January 2014, DNI officials said that metrics to measure quality of investigative reports had not been established.
GAO reported in 2010 that executive branch agencies do not consistently and comprehensively track the extent to which reciprocity is occurring because no government-wide metrics exist to consistently and comprehensively track when reciprocity is granted. The acceptance of a background investigation or personnel security clearance determination completed by another authorized agency is an opportunity to save resources and executive branch agencies are required by law to grant reciprocity, subject to certain exceptions, such as completing additional requirements like polygraph testing. GAO's 2010 recommendation that the leaders of the security clearance reform effort develop metrics to track reciprocity has not been fully implemented.