In a report dated December 19, 2008 the Government Accountability Office (GAO) provided a preliminary assessment of the timeliness and quality of the Department of Defense‘s (DoD) personnel security clearance program. GAO found that in fiscal year 2008 the Office of Personnel Management (OPM) completed 80% of all initial clearance investigations in 87 days. Although this represents a significant improvement over prior years; the existing clearance process may not be able to meet the December 2009 requirement of 90% in 60 days as mandated by the Intelligence Reform and Terrorism Prevention Act.

Using a sample of 100 favorably adjudicated investigations, GAO found that an estimated 87% of the OPM investigations in July 2008 for Top Secret clearances were missing at least one investigative element required by federal standards. The numbers of elements missing from the 100 investigations were:

Employment 33 Residence 17 Spouse Records 8
Social References 32 Education 16 Financial 3
Forms 31 Subject Interview 12 Former Spouse 2
National Records 18 Local Records 9

The report acknowledged the current clearance reform project that is scheduled to be implemented over the next 20 months, including two new tools for assessing investigative and adjudicative quality.

GAO’s representation of missing investigative elements is somewhat misleading. For instance in the report’s footnotes GAO explained that the 12 investigations missing a Subject Interviews were due to the Subject’s [military] deployment. OPM routinely closes such cases and forward them to the requestor without conducting the Subject Interview. It is then the responsibility of the requestor to have the investigation reopened when the Subject returns from deployment. How many employment and social references were not interviewed because they too were deployed with the same military unit as the Subject? How many of the missing forms were financial or medical releases that have absolutely no adjudicative value?

When one or more elements of an investigation are missing, it doesn’t always mean that the investigation is deficient. Likewise, granting a security clearances based on such investigations due to military exigencies is often justifiable and permitted by DoD regulation. GAO’s report claims to assess quality, but it admits that it made no judgments about the adequacy of the investigative reports to support [adjudicative] decisions. Were they just counting beans?