ODNI Has Taken an Initial Step to Implement Continuous Evaluation across the Executive Branch but Has Not Determined Key Program Aspects or How it Will Monitor and Measure Performance

In October 2016, ODNI took an initial step to implement continuous  evaluation across the executive branch in a phased approach, but as of  May 2017, it had not yet formalized the program in policy. This is due, in part,  to the fact that ODNI has not yet determined key aspects of the program,  such as when the future phases of implementation will occur or what they  will entail, and none of the agencies has completed implementation plans. For the first phase of  implementation, executive branch agencies are to conduct certain  continuous evaluation record checks against a portion of their national  security population. Specific  details of ODNI’s pilot were omitted from this report because the  information is sensitive. OMB concurred with the  recommendation. ODNI Lacks Plans for Monitoring and Measuring Continuous Evaluation Program Performance

ODNI lacks a plan to monitor and measure the performance of continuous  evaluation across executive branch agencies. Without developing a plan to monitor continuous evaluation—including  assessing continuous evaluation at various phases of implementation— ODNI cannot ensure that continuous evaluation is being conducted  consistently across the executive branch, and it may experience  challenges in identifying any needed modifications to the program. DOD and State Have Designed, Piloted, and Evaluated Continuous Evaluation to Varying Extents

DOD and State have designed, piloted, and evaluated continuous  evaluation, although their respective approaches have varied in scope,  size, and duration—with DOD’s pilot involving the most record checks,  the largest population, and the longest duration. As previously discussed,  DOD’s efforts to design, pilot, and evaluate continuous evaluation have  been ongoing for more than a decade, and they pre-date efforts at ODNI  to develop and implement an executive branch-wide continuous  evaluation program. Specifically, the department  expanded enrollment to 225,000 DOD clearance holders in December  2015 and 500,000 in December 2016, and it plans to increase the  enrolled population to 1 million by the end of calendar year 2017. The  department has also set an internal goal to enroll all clearance holders  department-wide by the end of fiscal year 2021. Number of Agencies Meeting Periodic Reinvestigation Timeliness Goals Decreased from Fiscal Years 2012- 2016, and Potential Continuous Evaluation Effects Are Unknown

The number of executive branch agencies meeting established timeliness  goals for completing periodic reinvestigations decreased from fiscal years  2012 through 2016. Specifically, while 84 percent of the executive branch agencies met the 150-day  investigative goal for at least three of four quarters for the fastest 90  percent of periodic reinvestigations in fiscal year 2012, only 18  percent of the agencies met the investigative goal in fiscal year  2016. while 84 percent of the executive branch agencies met the end-to-end  processing goal of 195 days for at least three of four quarters for the  fastest 90 percent of periodic reinvestigations in fiscal year 2012, only  22 percent of the agencies completed their fastest 90 percent of  periodic reinvestigations within 195 days for at least three of four  quarters in fiscal year 2016. Specifically, all five agencies stated that continuous evaluation will  increase their workloads—and therefore costs—if no other changes are  made to the personnel security process. Senior DOD officials stated that DOD cannot afford to conduct both  continuous evaluation and periodic reinvestigations. Specifically, DOD  estimates that implementing the 2012 Federal Investigative Standards  requirement to conduct more frequent periodic reinvestigations for certain  clearance holders will cost approximately $1.8 billion for fiscal years 2018  through 2022. Although executive branch agencies have identified increased resources  as a risk associated with implementing continuous evaluation, and ODNI  has acknowledged that risk, ODNI, in coordination with the PAC, has not  assessed the potential effects of continuous evaluation on an agency’s  resources. Further, without assessing the potential impacts on agency resources and  developing a plan to address them—once ODNI has further defined the  program—implementing continuous evaluation could further increase the  periodic reinvestigation backlog and agency costs. Accordingly, the program’s  implementation has been delayed for almost 7 years. Without a Security Executive Agent Directive  for continuous evaluation that provides an expanded definition of  continuous evaluation and relevant terms to help ensure consistent use; a  plan for implementing continuous evaluation across the executive branch,  that includes future phases of implementation and expectations for  agencies; and a plan for monitoring program performance throughout the  implementation process, as well as performance measures by which to  track and report progress, ODNI is not well-positioned to ensure the  success and effectiveness of the continuous evaluation initiative. (Recommendation 5)
The Director of National Intelligence should, once ODNI has further  defined the continuous evaluation program, to include issuing a  Security Executive Agent Directive and developing an implementation  plan, in coordination with the Deputy Director for Management of the  Office of Management and Budget in the capacity as Chair of the  Security, Suitability, and Credentialing Performance Accountability  Council, assess the potential effects of continuous evaluation on  agency resources and develop a plan, in consultation with  implementing agencies, to address those effects, such as modifying  the scope of periodic reinvestigations, changing the frequency of  periodic reinvestigations, or replacing periodic reinvestigations for  certain clearance holders. We continue to believe that our  conclusions are valid, as discussed below. As a result, full  implementation—which has been delayed for almost 7 years—may be  further delayed.
Why GAO Did This Study

Continuous evaluation is a key executive branch initiative to more frequently identify and assess security-relevant information, such as criminal activity. Implementing a continuous evaluation program has been a long-standing goal, with implementation milestones as early as 2010 and DOD pilots dating back to the early 2000's.
GAO was asked to review efforts to implement continuous evaluation. This report assesses the extent to which (1) ODNI has implemented an executive branch-wide program and developed plans to monitor and measure its performance; (2) DOD and other agencies have designed, piloted, and evaluated continuous evaluation and (3) agencies completed timely periodic reinvestigations from fiscal years 2012-2016, and the potential effects of continuous evaluation on reinvestigations. GAO reviewed documentation, analyzed timeliness data, and interviewed officials from ODNI and other agencies. This is a public version of a sensitive report that is being issued concurrently. Information that ODNI and State deemed sensitive has been omitted.

What GAO Found

In October 2016, the Office of the Director of National Intelligence (ODNI) took an initial step to implement continuous evaluation—a process to review the background of clearance holders and individuals in sensitive positions at any time during the eligibility period—across the executive branch, but it has not yet determined key aspects of the program, and it lacks plans for implementing, monitoring, and measuring program performance. For the first phase, agencies are to conduct certain continuous evaluation record checks against a portion of their national security population by the end of fiscal year 2017. However, ODNI has not formalized its policy on what continuous evaluation encompasses, determined what the future phases will entail or when they will occur, or developed an implementation plan. According to all seven agencies GAO interviewed, this uncertainty has affected their ability to plan for the program and estimate its costs. Without a continuous evaluation policy and a fully developed plan, full implementation—which has been delayed since 2010—may be further delayed. Moreover, ODNI lacks a plan to monitor and measure program performance, including for the first phase, which is underway. Without developing such a plan, ODNI cannot ensure that the program is being implemented consistently across the executive branch or that it is effectively identifying risks to national security.
The Department of Defense (DOD) and the Department of State (State) have designed, piloted, and evaluated continuous evaluation. Their approaches have varied in scope, size, and duration, as they pre-date ODNI's efforts to implement continuous evaluation executive branch-wide. DOD's pilot involves the most record checks and the largest population. DOD had 500,000 employees enrolled in December 2016, and it plans to enroll 1 million by the end of calendar year 2017 and all clearance holders by the end of fiscal year 2021.
Executive branch agencies meeting established timeliness goals for completing periodic reinvestigations decreased from fiscal years 2012 through 2016, and the potential effects of continuous evaluation, including on reinvestigations and resources, are unknown. While 84 percent of the executive branch agencies reviewed by GAO reported meeting the executive branch's 195-day timeliness goal for at least three of four quarters in fiscal year 2012, only 22 percent did so in fiscal year 2016. Also, a 2008 report outlined a plan to replace reinvestigations with continuous evaluation, but ODNI documentation indicates that this is no longer the intent. While agencies expressed varying views about changes to reinvestigations—such as modifying their scope—officials from five agencies stated that the continuous evaluation program will increase their workloads and costs if no other changes are made to the requirements. DOD officials said they cannot afford to conduct both continuous evaluation and reinvestigations, as DOD estimates that more frequent reinvestigations for certain clearance holders will cost $1.8 billion for fiscal years 2018 through 2022. Although agencies have identified increased resources as a risk of the program, ODNI has not assessed the program's potential effects on agency resources. Without assessing the potential effects once ODNI has further defined the program, implementing continuous evaluation could lead to further delays and backlogs in reinvestigations, and could increase agency costs.

What GAO Recommends

GAO is making six recommendations, including that ODNI formalize its policy on continuous evaluation, develop an implementation plan as well as a plan to monitor and measure program performance, and assess the potential effects of continuous evaluation on agency resources. ODNI concurred with the recommendations, but disagreed with aspects of GAO's conclusions. GAO continues to believe the conclusions are valid, as discussed in the report.