This section explores the course of events that shaped the personnel security clearance process.
The history is fairly long and complicated. However, certain specific events give a clear understanding of how the security clearance process has evolved since 1972, and the difficulties the US Government has faced. It’s important to recognize that federal security clearance processing does not exist within a single monolithic structure with one agency conducting investigations and one agency making clearance decisions.
There are dozens of federal agencies that process clearances. All agencies use the same basic procedures and standards for granting or denying clearances, but many agencies use their own resources to make clearance decisions.
Most agencies use the Office of Personnel Management (OPM) as their Investigation Service Provider (ISP), but many agencies have statutory or delegated authority to use other ISPs or their own internal investigative personnel. Consequently there are significant differences in the time it takes to complete a security clearance.
About 87% of all Personnel Security Investigations (PSIs) are conducted on DoD personnel (federal employees, military, and contractors). The next largest are DHS (including its component agencies) at about 3% and DoE at about 1.2%. Each of the other agencies processes only a fraction of 1% of the 850,000 PSIs conducted each year. Because the DoD personnel security program dwarfs the combined size of all other federal agency programs, it’s necessary to focus on DoD when discussing security clearance processing.
In 1972 the responsibility for Army, Navy, Air Force, and DoD contractor PSIs was transferred to the newly created Defense Investigative Service (DIS). A DoD Personnel Security Working Group (PSWG) published a report in April 1975 documenting the lack of standardization throughout the personnel security program. The PSWG reported that adjudications for collateral clearances were being performed in several thousand locations across DoD and repeated criticized the inconsistencies in adjudicative decisions. It also recommended that the number of different types of PSIs be reduced. Many of the PSWG’s recommendations were implemented during the 1970’s and 1980’s, including the consolidation of several thousand adjudicative offices into 18 DoD Central Adjudication Facilities (CAFs).
In December 1979 DoD Directive 5200.2, Personnel Security Program, and its implementing regulation, DoD 5200.2-R were issue, and for the first time, most of the elements of personnel security were standardized throughout DoD. In 1981 the first formal Adjudicative Guidelines were established and incorporated into DoD 5200.2-R.
From its inception DIS was understaffed and had 48,000 pending cases (twice its optimum workload), many of which were overdue. From 1974 to 1985 its workload increased over 58% with 17% fewer investigators than the military had to do the job prior to 1972. A General Accounting Office (GAO) report in 1981 estimated that delays for initial clearances were costing the Government $920 million a year in lost productivity. That same year DIS imposed a moratorium on conducting Periodic Reinvestigations (PRs) for clearances involving access to Sensitive Compartmented Information (SCI), in order to deal with a large backlog of requests for initial investigations. In 1983 it resumed these PRs and also began conducting PRs for collateral Top Secret clearances. In 1985 the “Stillwell Commission” report recommendations resulted in additional funding for DIS and PRs for Secret clearances. DIS had about 850 field investigators at the time and began adding additional personnel. In 1991 it reached a high point of about 3,100 investigative personnel, including 2,400 field investigators. However, in anticipation of a reduction in security clearance requests because of the “peace dividend” resulting from the end of the Cold War, a hiring freeze was imposed. A 48% reduction-in-force occurred over the following 3 years and left DIS with about 1,600 investigative personnel of which 1,250 were field investigators.
During a second reform effort in the 1990’s, the number of DoD CAFs was further reduced from 18 to 8, and the types of PSIs were reduced to 3. The Single Scope Background Investigation (SSBI) increased the amount of investigative work required for Top Secret clearances, and a “neighborhood investigation” component was added to the SSBI-PR. With only half the investigative personnel it previously had, DIS was forced to implement a quota system for PRs, restricting the number of requests defense agencies were allowed to submit. Nevertheless the backlog of cases at DIS began to grow. In 1998 the new investigative standards required by Executive Order 12968 were issued. The implementation of these standards immediately resulted in a “backlog” of 400,000 PRs, most of which were required by the new standards but not yet submitted to the Defense Security Service (DSS), which had changed its name from DIS 2 years earlier.
In 2000 DoD began shifting a large portion of security clearance investigations from DSS to the Office of Personnel Management (OPM). OPM was previously responsible for conducting federal employment suitability investigations (including those for DoD), as well as a relatively small number of security clearance investigations for other federal agencies. In 1996 OPM disestablished its Office of Federal Investigations and privatized the field portion of that organization through the creation of the US Investigations Services (USIS) under an Employee Stock Ownership Plan (ESOP). USIS was awarded a 3-year non-competitive contract to conduct investigations for OPM.
Foreshadowing the requirements of the Intelligence Reform and Terrorism Prevention Act (IRTPA), the 2004 Defense Authorization Bill directed DoD to begin submitting almost all of its security clearance investigations to OPM in early 2004, and DSS investigators began conducting those investigations under OPM control.
According to a 2004 GAO report, DSS and OPM had a combined investigative staff of 4,200 government and contractor personnel. OPM estimated that about 8,000 were needed. The average turnaround time for an SSBI hit a high of about 396 days.
In December 2004 the IRTPA became law. It required that, to the extent possible, all executive branch security clearance investigations be conducted by one agency. It also required that 90% of all security clearances be completed in an average of 60 days by December 2009. In January 2005 GAO designated the DoD Personnel
Security Program as a high-risk program. In March 2005 1,600 federal investigative personnel officially transferred from DSS to OPM. By the end of 2005 the Federal Investigative Services Division of OPM increased its combined contractor and federal work force to about 8,000, including 6,500 field personnel. By 2008 OPM investigative staff reached a high of 9,421 personnel, but has declined somewhat since then. Unlike DSS, which was an appropriated fund activity, OPM conducts investigations on a fee-for-service basis and has the authority to set the prices it charges other Government agencies for the investigations they request. The combination of being paid for the investigations it conducted and using contract investigators to do the majority of the work afforded OPM the flexibility to rapidly adapt to changes in the number and type of investigations it conducted.
Gradually the backlog of cases and the average turnaround time for investigations began to decline. In early 2007 the Office of Management and Budget (OMB), the Office of the Director of National Intelligence (ODNI), OPM and DoD created a Joint Security and Suitability Reform Team (JSSRT) to completely revamp and unify the process. The JSSRT issued its initial report in April 2008 outlining a general framework for near and long term goals to modernize and streamline security clearance, employment suitability, and access to federally-controlled facilities and information systems government-wide. In December 2008 the JSSRT issue a progress report detailing the changes it initiated and planned to implement over an 18 month period. Some of these changes were implemented on schedule, some were delayed, modified, or partially implemented, and new changes were added. Full implementation of all the original or modified changes will probably not occur until 2014.
The most notable events that have occurred since 2008 are:
Aug 2009 Secure Web Fingerprint Transmission (SWFT), a web-enabled biometric system, became available to defense contractors to transmit electronic fingerprints to OPM for security clearance applicants. Federal contractors will be required to submit all fingerprints via SWFT by December 2013.
Apr 2010 The Case Adjudication Tracking System (CATS) became operational at all major DoD Central Adjudication Facilities. This enabled the electronic transfer of completed investigations from OPM and conversion of these files to a machine readable format. It resulted in reducing the transfer time by 50% and permitting electronic adjudication (eAdjudication) of about 25% of Secret clearance investigations.
Jul 2010 The Defense Central Index of Investigations (DCII) was transferred from DSS to the Defense Manpower Data Center (DMDC). This completed the transfer of DoD Personnel Security IT Systems from DSS to DMDC.
Previously the Joint Personnel Adjudication System (JPAS), the Secure Web Fingerprint Transmission (SWFT), and the improved Investigative Records Repository (iIRR) were transferred from DSS to DMDC. These systems will eventually be integrated into the Defense Information Systems for Security (DISS) along with the Industrial Security Facility Database (ISFD) and Educational Network Registration and On-Line Learning (ENROL). DISS also provides Automated Records Check (ARC) and eAdjudication functionality and is the single point of entry for DoD personnel security.
Oct 2010 The Enhanced Subject Interview (ESI) replaced the Personal Subject Interview (PRSI) as a standard component of all Single Scope Background Investigations (SSBIs), Background Investigations (BIs), and Moderate Risk Background Investigations (MBIs). It also partially replaced the Special Interview (SPIN) required on investigations for Secret clearances when an interview of an applicant is needed to resolve unfavorable information.
Oct 2010 OPM eliminated the Limited Investigation (LI), the Periodic Reinvestigation—Residence (PRI-R), and the Public Trust Special Background Investigation (PTSBI), which had previously
been used for Public Trust positions.
Feb 2011 The Government Accountability Office (GAO) reported removal of the Department of Defense (DOD) Personnel Security Program from its list of High Risk Programs, because of improvements to the program since it was first placed on the list in 2005.
Sep 2011 December 2010 version of the SF86 (Questionnaire for National Security Positions) was fully implemented.
Dec 2011 Title 5 Code of Federal Regulations Part 731 (5 CFR 731), “Suitability,” was changed to require Periodic Reinvestigations (PRs) on all “covered” Public Trust positions at 5-year intervals. PRs were previously not required by 5 CFR 731.
Aug 2012 Six DoD Central Adjudication Facilities (CAFs) began consolidating into a single a CAF. The consolidation is expected to be completed by January 2013. By September 2013 the new DoDCAF is expected to expand its responsibilities to adjudicating federal employment suitability and Homeland Security Presidential Directive 12 credentialing determinations. The 3 other DoD CAFs (National Security Agency, Defense Intelligence Agency, and National Geospatial Intelligence Agency) are not included in the consolidation.
Overall the Government has met the IRTPA timeliness requirement to complete 90% of initial clearances in an average of 60 days, but major problems involving reciprocity of security clearances still exist and a single integrated database of all security clearances has not been created. OPM has significantly reduced the time it takes to conduct investigations, but the quality of investigations has declined and increased the time required to adjudicate problematic cases.
In 2013 the interval for Periodic Reinvestigations (PRs) for Confidential and Secret clearances will be shortened to 5 years, and in 2014 PRs for Top Secret clearances will be conducted annually. The scope of an investigation for a Top Secret clearance will change significantly. There will be a greater reliance on a combination of commercial and government database searches and a reduction in the number and type of interviews and record checks conducted by field investigators.
– compiled by ClearanceJobs.com.