Plan Revamps Security Clearance Process

August 2008
By Maryann Lawlor
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Senior Airman Bernard Lee, USAF, Multinational Force–Iraq (MNF-I), plays the part of a contractor during a retinal scan demonstration at the MNF-I badging office. The scan is part of the security clearance and identification process for issuing official badges to contractors at the Ali Base in Iraq.
Automated processes target bottlenecks in current procedures.

Say the words “security clearance” in a conversation with defense contractors, and the vast majority has a tale to tell of long waits and missed opportunities. Those two words have people in Washington, D.C., talking too. For two years, the organizations in charge of the security clearance process have worked hard to improve it. But for many, the time for revamping the old is over, and the time for creating a new process has begun.

Some experts who have followed promises of improvement for decades say talk is cheap and change costs money—the one element that has been missing from many of the plans. While the Security and Suitability Process Reform plan does not address this specific issue, it does focus on a number of problems that have been the downfall of patchwork solutions. A 15-month collaborative effort by the Joint Security and Suitability Reform Team, known as the Joint Reform Team, composed the plan in response to a presidential directive issued on February 5, 2008. The team comprised members of the Office of the Director of National Intelligence, the U.S. Defense Department, the Office of Personnel Management (OPM), the Office of the Assistant to the President for National Security Affairs and the Office of Management and Budget (OMB).

The plan outlines a number of steps that would be taken in the very near future to modernize and streamline security clearance processes governmentwide. Analysis of current procedures and new technologies concluded that the federal government is now ready to implement a process that collects and validates more relevant information at the application stage. The increased use of technology will expedite the process by reducing the work now conducted by humans. Field investigative activity will focus on collecting and validating specific information. Rather than trying to avoid all risk by spending an equal amount of time on each applicant’s information, the new approach is designed to shift attention—and resources—to applicants who may pose a greater risk if they were allowed to handle classified material. When cleared personnel move to a different agency or company or request a change in a clearance level, data relevant to the change will be used to make hiring and clearing decisions. This change aims at reducing the duplication of requests and ensuring consistent quality and standards. By using more frequent automated database checks to identify security-relevant issues, continuous evaluation techniques will replace periodic reinvestigations of personnel who already have a security clearance.

Under the plan, an Executive Branch governance structure will ensure hiring and clearing decision processes are effectively coordinated. A Performance Accountability Council, led by OMB’s deputy director for management, will be accountable to the president to achieve reform goals. A security executive agent will consolidate security clearance responsibilities that are currently spread out among diverse members of the security community. The plan affirms OPM’s role as suitability executive agent.

Several actions will be taken in the near term to achieve the changes set forth in the plan. First, a next-generation application that collects more relevant applicant information at the beginning of the application process will be developed. Second, “clean” Secret case files will be handled through automated adjudication, freeing personnel to focus on more complex cases. Third, automated record check capabilities will be developed for new cases; these capabilities are essential to the implementation of continuous evaluation of security clearance holders. Fourth, an information technology strategy will be designed that enables these improvements to take root throughout the government.

As the OMB official responsible for improving the security clearance process since June 2005, Clay Johnson III, deputy director for management, is confident that this new reform plan is heading in the right direction. During the first two years after he was handed the task, Johnson and his team addressed immediate needs to make the existing system work. With a shortage of adjudicators and only about a third of the number of investigators needed to handle the volume of security clearance applications pouring in, the first task was hiring. “OPM had already started to make efforts to add a lot of private contractors, primarily investigators; and every agency that didn’t have enough adjudicators increased its staff,” he explains.

To improve the current system, Johnson’s team members set specific performance goals, and perhaps more importantly, started holding themselves accountable for meeting those goals. According to Johnson, the increase in capacity and accountability reduced the amount of time needed for the investigation and adjudication stages from 160 days to about 112 days as of February 2008. “Our long-term goal—by December of 2009—is to complete these stages in 60 days, so we want to reduce it by a total of 100 days,” he says.

With these improvements in place, work began in earnest on a total transformation of the process. It started with rethinking how and what information is collected and how this could be done faster, better and more cost effectively.

“One of the things that became really clear to me within weeks of pulling everyone together [for the Joint Reform Team] was that everybody really, really, really wants to fix this. Everybody has had a really bad experience—at least one—and they know firsthand that it doesn’t work. There are no naysayers. There’s nobody who says we really don’t need to do this. The difference of opinion is how quickly we can do it. Why does it take six months to bring this onboard? Why can’t we do it in three months or three weeks or three minutes? The frustrations associated with this will not be getting it done or not, it’s getting it done as quickly as we all would like,” Johnson maintains.

Chief Petty Officer Robert F. Hebron, USN, command master-at-arms assigned to the guided missile cruiser USS Normandy, demonstrates the proper fingerprinting technique for background investigations to obtain a security clearance. One of the primary issues with the current security clearance process is that it does not feature a system for using digital fingerprints. The Security and Suitability Process Reform plan addresses this problem.
Automating much of the process will be key to reducing the time it takes to obtain a clearance. For example, the plan calls for applicants to provide more information on a newly designed electronic application form. In many cases, an investigator would have asked for this data during the interview stage. As envisioned, the form also will be designed to reformat automatically and ask different or additional questions based on an applicant’s answers. These standardized branching questions and quality control checks will be agreed to and finalized by participating agencies by the end of 2008, the plan states.

“The application is very, very important because a very large percentage of the issues that a particular applicant might have are self-identified in the application,” Johnson notes. The issues can include items such as extensive foreign travel, he explains.

Developing the electronic application (eApplication) is one near-term goal that will help increase automation and infuse flexibility into the process. The eApplication also will be integrated into other technologies to facilitate an end-to-end process. According to the reform strategy, a complete project plan—including the means to process electronic attachments, signatures and fingerprints—will be finalized this year as requirements and system capabilities are identified and analyzed.

“Once they fill out the application and press ‘send,’ what we envision is that—and this will all be in the details to follow, and the devil is in the details—automatically, without human intervention, certain database checks will be made to confirm information such as does the person have the advanced educational degrees that he or she claims? Does he truly not have credit problems?” Johnson explains.

Automation also will play a part in the adjudication phase of the process. Using an eAdjudication decision support capability, portions of the current caseload for Secret clearances will be processed faster. The initial step to putting this technology into action will be revisions to government policy. Once the policy is in place, eAdjudication will be implemented for Secret clean cases by the end of 2008. A program will be put into place to check eAdjudicated cases manually to ensure quality. This quality assurance piece is a long-term project.

Some of the Joint Reform Team’s research led to more questions about the practicality of some current processes. For example, an automated records checks (ARC) capability could replace several of the traditional elements of the investigation stage. It may replace some of the costly and time-consuming work in following up leads in Secret clearance applications and as a tool during the first three days of a Top Secret clearance investigation. In addition, the ARC may be deployed annually to review information about Top Secret clearance holders and within a five-year period for personnel who have a Secret clearance. This ability to review cleared personnel continuously may be more cost effective and beneficial than current procedures that call for reinvestigations every several years, the plan states, but the team is calling for more research to determine the return on investment.

Much of the transformation of the security clearance process hinges on information technology. The goal is to develop capabilities that can be used end-to-end, replacing the government’s existing multitude of systems that have similar functionalities but limited interoperability. They are primarily used to track hard-copy case files.

An end-to-end technology demonstration has been scheduled to determine the requirements for information technology investments. Results of the demonstration are expected by the end of fiscal year 2008. These results not only will influence the long-term information technology strategy that supports the ultimate enterprisewide approach but also will outline a transition strategy.

Additional plans for calendar year 2008 activity include clarifying government policy regarding the continuous evaluation of cleared personnel, modifying Standard Form 86 to permit research as part of the investigative routine and incorporating branching questions in the applications. In addition, a strategy will be developed to ensure that standard and criminal record checks continue to be conducted to mitigate gaps in automated record systems. The plan also calls for an analysis of data on application submission errors to identify which quality controls will be needed in the eApplication.

In 2009, the Joint Reform Team is calling for the continued procurement and deployment of worldwide electronic fingerprint stations as well as the development of the initial operational capability of the ARC for federal government use.

One issue the team hopes the thoroughness of this plan will address is reciprocity. Although government agencies are required to accept a security clearance that originated in a different agency, some still do not. In general, these organizations claim that the adjudication conducted by another agency or specific items on the application—such as a drug conviction from 20 years ago—negate acceptance in their department. Standardizing the process should address most of these concerns, with very few exceptions, Johnson says. If agencies refuse to comply, their right to authorize security clearances could be terminated, he adds.

“I think the general feeling in the federal government is that there’s not as much accountability as anybody would like. Federal government people say this, and they’re not proud of it. Well, in this case, we’re holding them accountable. The way you hold them accountable is that you’re really clear about what the goal is and by what time you expect them to achieve it. Then they agree to the goal, and you make it really clear between the two of you—between two agencies or two individuals—the steps they’re going to take and by when they are expected to get there. Then you monitor the performance. And it’s made really clear that this is important and will be done as promised. If the answer to any of that is no, we’ve got a problem, and you go to people’s bosses. We’re focusing on results and performance,” Johnson states.

Although the plan aims at reducing workload by automating many of the current procedures, one item that is likely to increase is the requirement for funding to purchase and install new systems. To address this issue, Johnson reveals that the Defense Department has decided to scrap the idea of upgrading its primary security clearance technology, the Joint Personnel Adjudication System, and invest instead in a replacement that can be used governmentwide.

In addition, the OPM has set aside part of the fees it collects from agencies to conduct investigations to improve systems and purchase new technologies.

“But one of the things we need to do—and our committed timeframe on this is this year —is to identify what kinds of investments are made. We need to confirm and assure ourselves, Congress and industry that the money is there to make the kind of investments we need. We need to lay out the timetable by which these various reforms will be implemented and when we think the reforms will begin to impact—demonstratively so—the timeliness of security clearance determinations,” Johnson says.

Web Resources
Office of Management and Budget:
Security and Suitability Process Reform plan:

GAO Scrutinizing Clearance Reform Plan

The U.S. government’s watchdog agency will be keeping a close eye on activity surrounding the Security and Suitability Process Reform plan. After all, the Government Accountability Office (GAO) has been examining the personnel security clearance processes for more than three decades, so it has seen a lot of plans come and go.

But more recently, Brenda Farrell, director, Defense Capabilities and Management, GAO, testified about the topic before the Subcommittee on Oversight of Government Management, the Federal Workforce and the District of Columbia. The subcommittee is under the U.S. Senate’s Committee on Homeland Security and Governmental Affairs. What she described was a process that was in need of reform in four areas: requirements determination, quality assurance, metrics and long-term funding requirements.

On many occasions, GAO officials have pointed out several concerns not only about the lengthiness of the process but also about the quality. Since 2005, the U.S. Defense Department’s security clearance program has been one of several programs on the GAO’s “High-Risk List,” an inventory of items that could threaten national security. The goal of the list is to raise the visibility of an issue.

“You certainly don’t want people running around with security clearances that shouldn’t have them. And we’ve had a lot of concerns not only about the timeliness issue and that they need to expedite those clearances but also about the quality. We’ve stressed—especially in the last few hearings—that it’s not going to serve any purpose to have an expedited security clearance if it’s not worth the paper it’s written on,” Farrell states.

“As far as we can tell, there’s no quality at all. What good does it do to push these things through if nobody’s taking the time to make sure that all the pieces are there? And we’re not talking about missing ZIP codes,” she relates. When the agency reviewed security clearance materials for completeness in 2006, the types of information they found missing from investigative files were “alarming,” she adds.

The GAO has pointed out that the current system lacks the metrics to measure quality. For example, while the security clearance process comprises six phases, the Office of Personnel Management (OPM) only has metrics to measure the quality of the investigative stage. “That’s one thing that we’re going to be looking at very carefully with this reform effort. Where are they building quality into the process, and then where are they establishing quality metrics so that they can know how well they’re doing and have something with which to mitigate risk?” she maintains.

One of two GAO initiatives currently underway will examine if timeliness and quality improvements have actually occurred since 2006, when the agency looked at these topics in depth. Results from this effort are expected by the end of 2008 and will help determine if the program should remain on the High-Risk List.

Farrell reveals that although the assessment is not complete, GAO has many questions about how OPM counts the number of days it takes to obtain a security clearance. The Office of Management and Budget (OMB) relies on the numbers OPM reports. This leads to the claim that it is nearing the requirement set in the Intelligence Reform and Terrorism Prevention Act of 2004 to complete at least 90 percent of all applications for personnel security clearances within an average of 60 days after receiving the completed application from an authorized investigative agency.

“One of the questions we have is when does the process start? You’re trying to measure timeliness end to end, and we’ve had some questions and a lack of agreement with OPM and OMB about when the process starts. Then there are other issues. ‘Closed Pending’ is one of the favorite ones, where OPM would actually suspend an investigation while waiting for some additional information, but they call it ‘Closed Pending.’ While it was closed, they weren’t counting the time, but when the information came in, they’d start that up like a new one. You can see how that would offset the actual time of investigation. Now we’re hearing from OPM that they’ve made progress in this area and that they’re not actually counting those, but they still have the term, and we’ve seen it reflected in some of their materials,” Farrell says.

The second GAO initiative was an assignment from the House Permanent Select Committee on Intelligence to review the reform plan using its prior work as the criteria. Because this task order came from the committee and work is still underway, Farrell cannot comment about progress to date. However, she compliments the level of attention the topic has been given by the highest levels in the federal government.

The change in administrations early next year could affect the efforts outlined in the reform effort, but Farrell is optimistic. “They [Joint Reform Team members] are trying to get it far enough along and visible enough so that it will be on the next administration’s radar screen and hopefully they’ll pick it up. But we are going to have to stay tuned,” she states. 


Industry Cautiously Optimistic About Changes to Processes

Industry is one sector that has a large stake in improving the security clearance process. While clearances for contractors make up only about 20 percent of the workload for the Office of Personnel Management (OPM), the effect on companies can be 100 percent of opportunities lost because they do not have enough secured personnel to bid on a contract. Organizations that represent industry have been active in trying to improve the timeliness of the process and endorse the Security and Suitability Process Reform plan.

Nine organizations, including AFCEA, have formed the Security Clearance Reform Coalition. Trey Hodgkins, senior director of defense and intelligence programs, Information Technology Association of America (ITAA), Arlington, Virginia, is one of its leaders. He explains that the coalition is focusing on process improvements that can occur in the existing system and supporting the plan the Executive Branch’s Joint Reform Team designed. “We think it goes in the right direction. We hope it will move as fast as they say it will move. There’s a lot of doubt about that,” he says.

Hodgkins explains that with the upcoming change in administration, industry will be the one consistent actor, and as such must ensure that the momentum for change stays strong. “Congress is going to have some changeover. Certainly the administration will have a lot of changeover, and it is going to fall to industry to be a major water carrier here to make sure that this remains a priority in the next administration. My biggest fear is that we’re not going to have this alignment of leadership that we currently enjoy. … To me, industry’s number one task is to see that the next administration builds this level of leadership commitment to change and then sustains that,” he states.

Members of the coalition were part of the discussions during the development of the Joint Reform Team’s plan. Many of the concerns and suggestions they expressed were addressed and accepted by the government team, Hodgkins notes. He is encouraged by the fact that the new plan promises consistency in the application process.

The improvements in the applicant questionnaire are likely to quicken the pace of security clearance approvals, he says. “On a case management level, it will be much more efficient than it is today, where you have Defense Department case management entirely disconnected from OPM case management. Cases that start in the Defense Department only have transparency as far as they’re touching it; the department doesn’t see what’s happening to the cases when they go to OPM. Then it’s reconnected again when it goes back to the department. It’s very disjointed. The new process will not be disjointed like that,” Hodgkins notes. One of the benefits is that this system preserves an electronic file so items such as credit reports and criminal records can be appended to it, he adds.

Another advantage of the new process is that it will enable the ability to capture and read digitized fingerprints. This is one of the drawbacks of some of the systems currently in place, including the Defense Department’s Joint Personnel Adjudication System.

In addition, the plan calls for technology that recognizes electronic signatures. The existing electronic application, called eQIP, requires applicants to print out the last two pages of the form, sign them, attach a fingerprint card and then mail them to OPM. “And you pray that OPM gets the electronic application and the mail arrives in time so that they can put it all together. And if they don’t have those three pieces, they won’t start the investigation. This is where we lose a lot of time,” Hodgkins points out.

Hodgkins is not the only one disillusioned by the current system. William Golden, chief executive officer and senior recruiter, IntelligenceCareers Incorporated, Woodbridge, Virginia, notes that changes to the system have been promised for more than 30 years and yet it is still broken.

Golden contends that change can only occur if resources are provided to support it. “At the end of the day, only the president can change things, but he can only change things if he gives money to change them. Well, the changes have not had money that goes with it [in the past], so the agencies have had no reason to cooperate, and they won’t. They say they will, but they won’t,” he states.

In some cases, even the corporate sector can be unwilling to change, Golden maintains. The law of supply and demand means that companies with more cleared employees are eligible to bid on more contracts.

Despite this advantage, the majority of the corporate sector realizes that the problems with the security clearance process are costing it money. Estimates are that as much as $8 billion worth of business is lost each year because companies cannot find enough cleared employees to fill government contract requirements, Golden shares. This also means that agencies are unable to complete their missions, he adds.

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