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 agencies that process clearances, and all agencies use the same basic procedures and standards for granting or denying clearances. Most agencies use the Office of Personnel Management (OPM) as their Investigation Service Provider (ISP), but some agencies have authority to use other ISPs or their own internal investigative personnel. Consequently, there are differences in the time it takes to complete a security clearance.
About 85% 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 more than 650,000 PSIs conducted each year for security clearances. 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, Air Force, Navy, Marine Corps, and DoD contractor security clearance investigations was transferred to the newly created Defense Investigative Service (DIS). However, security clearance adjudications continued to be performed in several thousand locations across DoD, and there were significant inconsistencies in adjudicative decisions. DoD eventually consolidated these offices into 18 DoD Central Adjudication Facilities (CAFs). This was later reduced to 9 DoD CAFs. In December 1979 DoD Regulation 5200.2-R, Personnel Security Program, was issued, 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.
The creation of DIS eliminated redundancy, centralized control of PSIs, and provided greater economy of scale for DoD. The Office of Personnel Management (OPM) also conducted PSIs for the federal Government, and together they conducted about 98% of all PSIs.
Throughout most of its history DIS was severely understaffed. Delays for initial clearances cost the Government $920 million a year in lost productivity. Eventually DIS grew from about 800 field investigators to 2,500 investigators. In 1996 most of OPM’s PSI function was privatized and contracted out to the US Investigative Service (USIS), which was created by former OPM investigators under an Employee Stock Ownership Plan, but later sold to private investors. Also during the 1990’s DIS changed its name to the Defense Security Service (DSS) and experienced a 50% reduction in the number of their field investigators in anticipation of a “Peace Dividend” that never materialized. New investigative standards implemented in the 1990’s, further increased the investigative backlog. When periodic reinvestigations became an unfunded requirement for Secret clearance in 1998, it immediately created a backlog of 400,000 overdue cases.
DSS began shifting some of its PSIs to OPM as early as 2000. In 2004 Congress passed the Intelligence Reform and Terrorism Prevention Act (IRTPA), directing that (to the extent possible) all PSIs be conducted by one investigative agency. DSS transferred its investigative staff to OPM, and after the transfer 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.
The IRTPA also required that 90% of all security clearances be completed in an average of 60 days by December 2009. In 2008 OPM investigative staff reached a high of 9,421 personnel, but 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. Some of these changes were implemented on schedule, some were delayed, modified, or partially implemented, and new changes were added. Security clearance reform became a continuous process often driven by unexpected events.
Other actions anticipated in the near future include a revision to the SF86, standardized reporting requirements for unfavorable information, and new Adjudicative Guidelines.
Questions and answers related to US Government security clearances, including those administered under the National Industrial Security Program (NISP), compiled by William H. Henderson.