Federal Suitability and Security Clearance Reform

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In December 2004 the Intelligence Reform and Terrorism Prevention Act (IRTPA) became Public Law 108-458. Title III of the IRTPA created the following requirements:

Responsibility—A single entity within the executive branch with responsibility for oversight of the security clearance process and a single agency to conduct, to the maximum extent practicable, security clearance investigations.

Integrated Database—A single consolidated database of all security clearances, allowing that certain records may be excluded for national security reasons.

Reciprocity—Prohibit duplicate investigations and require transferability and acceptance of investigations and clearances between federal agencies.

Timeliness—By December 2009 90% of security clearance determinations be made within an average of 60 days from date of receipt of a completed application.

The Office of Management and Budget (OMB) was given responsibility for security clearance process oversight, and the Office of Personnel Management (OPM) was given responsibility for conducting investigations. However, 21 other federal agencies are currently authorized to conduct their own security clearance investigations. OPM’s Central Verification System (CVS) provides a single search capability for 90% of all investigations and clearances. CVS does not provide access to records maintained in the Intelligence Community’s (IC) clearance database. Reciprocity continues to be problematic and defies implementation by fiat. Tremendous improvements have been made in clearance processing time by significantly increasing the number investigative and adjudicative personnel and through technological improvements. (See related article on “Security Clearances: How Long Do They Take?”)

In its 100 Day Plan released in April 2007, the Office of the Director of National Intelligence (ODNI) announced its intention to develop and implement security clearance process improvements. In August 2007 OMB, DOD, ODNI solicited proposals from industry to develop a new government-wide, end-to-end security clearance process. In fall 2007 a decision was made to align and integrate federal suitability, credentialing, and security clearance processes. The Joint Security and Suitability Reform Team (JSSRT) was created and issued its initial report in April 2008 recommending a new governance structure and outlining specific process reform initiatives. In its December 2008 report the JSSRT provided an implementation timeline for its reform initiatives. After the new administration took office in January 2009 there was a reevaluation of the reform effort. This resulted in some policy changes and changes to implementation dates of individual components of the reform process. The JSSRT (also called the Joint Reform Team—JRT) plans to have most of the processes shown below substantially operational by the end of this year. (Source: Security and Suitability Process Reform—Strategic Framework, February 2010, a joint report by OMB, DOD, OPM, and ODNI.)

eApplication—This is the new term for e-QIP (electronic Questionnaires for Investigations Processing). E-QIP has separate programs for each of the standard application forms. A new revised Standard Form 86—SF86 (Questionnaire for National Security Positions) was approved by OMB in March 2010 and should be implemented by the end of the year. OPM decided not to revise the other forms (SF85 and SF85P) until the SF86 was approved, because SF86 is the most comprehensive of the forms and changes in the SF86 will have a trickle down effect on the revision of the other forms. Approval of a revised SF85P (Questionnaire for Public Trust Positions) is expected by December 2011. (The new SF86 was previously planned to be implemented by December 2009.)

SWFTSecure Web Fingerprint Transmission system allows DOD requestors to submit fingerprints electronically. This will eliminate mailing time and permit more efficient matching of fingerprints with SF86s. It will also eliminate the time OPM spends scanning the paper fingerprint cards before they can be forwarded to the FBI. SWFT became operational at Defense Industrial Security Clearance Office (DISCO) in August 2009.

CATSThe Case Adjudication Tracking System is a program that allows a DOD adjudication facility to electronically receive a completed investigative file from OPM and convert it into machine readable format. Previously investigative files were mailed from OPM to DOD Central Adjudication Facilities (CAF). CATS is cutting case transfer time in half. CATS has been fully operational at DISCO, Army, Navy and Air Force CAFs since April 2010. Some non-DOD CAFs currently receive completed cases electronically from OPM as image files.

eAdjudication. CATS permits completed investigations received electronically by DOD CAFs from OPM to be screened by a computer program. This program can favorably adjudicate clean cases without human review. eAdjudication is only being used for Secret clearances, and 25 to 30 percent of these cases are being favorably adjudicated in this manner. Wider implementation of eAdjudication should take place by December 2012.

ARC—Automated Records Checks. The JRT expects initial operating capability within selected DOD populations by July of this year. The term ARC can be misunderstood, because OPM uses this term to describe their existing automated records checks. The JRT defines ARC as the integration of the existing OPM ARC with selected ACES (Automated Continuous Evaluation System) records checks, which include about 30 government and commercial databases coupled with the capability of electronically scoring the results. Pilot programs using ARC are planned for July, August, and December 2010. Initial operating capability for a new ARC should be in place by December 2010.

ESI—Enhanced Subject Interview. A Pilot Program is planned for sometime this year with full Implementation by June 2012. The ESI will be a modified version of what is currently known as a Personal Subject Interview (PRSI) enhanced by new SF86 branching questions and the results of an ARC. (ESI was previously planned to be operational by June 2009.)


EFI—Expandable Focused Investigation. This is a new term for Reimbursable Security/Suitability Investigations or what was simply known as investigative case expansion. A Pilot Program is planned for sometime this year with full implementation by December 2013. (EFI was previously planned to be operational by September 2010.)


Revised Investigative Standards—In September 2009 it was announced that the Federal Investigative Standards that were approved in December 2008 would have to be revised. The standards created a 3-tier concept that integrated employment suitability, credentialing, and security clearance investigations, with:

• Tier 1 – Low-risk and non-sensitive positions

• Tier 2 – Moderate-risk and non-critical sensitive positions

• Tier 3 – High-risk, critical-sensitive, and special-sensitive positions

All 3 tiers rely heavily on the ARC and EFI. They expect the new revised standards will be finalized by the end of this year. Once the revised standards are approved, incremental deployment in selected populations can begin with full implementation expected by December 2013.

CE—Continuous Evaluation. This term is a misnomer. CE will eventually replace what is now known as a Periodic Reinvestigation (PR) and will be done on a periodic basis rather than continuously, albeit more frequently than before. This is one of the areas of the new investigative standards that requires revision. CE operational capability for Top Secret clearances and special access programs will be available by October 2010, but until revised investigative standards are approved, CE can only be used to supplement a traditional PR. New CE standards will be established and operational for public trust positions by December 2012.

William H. Henderson is a retired security investigator, author of Security Clearance Manual, and regular contributor to ClearanceJobsBlog.com and ClearanceJobs.com.

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