There’s been a lot of improvement in case processing time over the past few years. Most of the improvement is directly related to the reduction in the backlog of cases. Since October 2006, the Office of Personnel Management (OPM), which conducts the vast majority of all security clearance investigations for the federal government, has reduced the number pending initial investigations that are more than 180 days old from about 99,000 to less than 1,500. They did this primarily by increasing their investigative staff. OPM currently has a combined federal and contractor investigative staff of about 8,500 personnel—about 6,500 of whom are field investigators. Ten years ago OPM and Defense Security Service together had half that many investigators. Seven intelligence agencies and 14 other federal agencies conduct their own security clearance investigations. The following chart shows the average processing time for the fastest 90% of initial security clearances by agency for the 1st quarter of Fiscal Year 2010 (October to December 2009):
|AGENCIES||PERCENT OF WORKLOAD||INITIATION TIME (DAYS)||INVESTIGATION TIME (DAYS)||ADJUDICATION TIME (DAYS)||TOTAL DAYS END-TO-END|
Source: Security and Suitability Process Reform—Strategic Framework, February 2010 A joint report by OMB, DOD, OPM, and ODNI
Notes: Agencies that receive investigative services from OPM are shown in blue and account for a combined total of 94.3% of the total workload.
Intelligence Community (IC) agencies that conduct their own investigations are shown in red and account for a combined total of 4.5% of the total workload.
Other agencies that conduct their own investigations are shown in green and account for a combined total of 1.2% of the total workload.
DHS HQ 1st quarter FY2010 data unavailable; data shown for 4th quarter FY2009.
In the chart “Initiation Time” is “the time in days from the date of submission by the applicant to the receipt date of all information/forms (PSI forms, releases, fingerprint cards, etc.) required to conduct an investigation by the investigative service provider.”
Compared to a few years ago, 78 days is a vast improvement for initial DOD industrial security clearances (cases processed by the Defense Industrial Security Clearance Office—DISCO). But 78 days is an average for the fastest 90%, and an average is just a mathematical calculation. Here’s a better approximate representation of how it looked for the entire DISCO applicant population in FY2009.
The fastest 90% include those cases taking up to 180 days. Most cases taking longer than 180 days are those that involve major derogatory information and those that require investigative activity in overseas locations.
There are 2 situations where time spent on case processing is excluded from the case completion times. Approximately 13.6% of DISCO cases were rejected by either DISCO or OPM due to errors on the Standard Form 86—SF86 (Questionnaire for National Security Positions) or the fingerprint cards. These cases must be resubmitted as new investigative requests. DOD-wide in FY2009 about 20% of all investigations were returned to OPM, because the investigations were incomplete. Probably more than half of these cases were sent back to OPM, when a Subject Interview was required and the Subject of the investigation, who had been in Iraq or Afganistan, returned to the U.S. The other cases were returned to OPM due to deficiencies in investigative scope, period of coverage, or case expansion to properly resolve and/or corroborate unfavorable information. When cases are returned to OPM, they are reopened as new investigations and the elapse time for the cases are reset to zero.
A new SF86 was approved by the Office of Management and Budget (OMB) in March 2010. This new SF86 will not be implemented until later this year. It is significantly more complex than the current SF86 and will probably increase the rejection rate. More than ever applicants with complicated personal histories will need help in filling out the SF86 properly. On the positive side, as more requesters begin to use SWFT, the Secure Web Fingerprint Transmission system, it should help lower rejection rates. Currently most fingerprints for DISCO cases are mailed to OPM. The mailed fingerprint cards sit in a bin at OPM until they are matched with the SF86. If fingerprint cards are not matched to an SF86 within 14 days, the SF86 is rejected, returned to DISCO, and the request for investigation must be resubmitted. SWFT will enable a more efficient matching of SF86s to fingerprint cards and eliminate the time OPM spends scanning paper fingerprint cards before they can be forwarded to the FBI.
For complex cases there is a 2-stage adjudication process at DISCO. DISCO is authorized to grant security clearances, but they lack the authority to deny or revoke a clearance. When the level of derogatory information in an investigative case file reaches a certain threshold, DISCO must refer the case to the Defense Office of Hearing and Appeals (DOHA) for adjudication. In past years DISCO has referred about 20% of its cases to DOHA; however in FY2009 DISCO only referred a little more than 5% of its cases to DOHA. No reason has been announced for this change. DISCO was probably given greater authority to adjudicate more complex cases, and by granting clearances in about 95% of its cases very early in the process, it has been able to reduce its average adjudication time.
DISCO interim Secret clearance decisions take about 3 working days. These decisions are based solely on a review of the SF86 and a review of federal investigative and security clearance databases. In FY2008 DISCO granted interim clearances in only 61% of its cases. When compared the 1% denial rate for final clearances, the 39% declination rate for interim clearances clearly shows the importance of providing as much issue mitigation as possible in the SF86, so that adjudicators have that information available when making interim clearance decisions.
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