The National Industrial Security Program Policy Advisory Committee (NISPPAC) recommends changes in industrial security policy. Their recommendations can influence modifications to Executive Order 12829, its implementing directives, and the National Industrial Security Program Operating Manual (NISPOM). NISPPAC also advises the Information Security Oversight Office (ISOO) on matters concerning the policies of the National Industrial Security Program (NISP) and serves as a forum to discuss policy issues.

NISPPAC was created in 1993 by Executive Order 12829, “National Industrial Security Program” and membership includes 16 representatives from executive branch agencies most affected by the NISP and eight representatives from companies involved with classified contracts. It has a number of working groups, including Personnel Security Clearance, computer Certification & Accreditation, Special Access Programs, and Performance Accountability Council.

NISPPAC meets two or three times a year, and the meetings are open to the public. Reports of each meeting are usually posted at the ISOO website three months after the meeting. Meetings almost always include presentations on industrial security clearance processing metrics by the Defense Security Service (DSS) and the Office of Personnel Management (OPM), which are members of the Personnel Security Clearance Working Group.

NISPPAC reports are the only source relatively current information on industrial security clearance processing trends, issues, and future developments. Reports from the past two meeting have included information about:

Fingerprint Policy

OPM rejects requests for investigation (cases) when fingerprints are not received within 14 days of receiving the cases. Prior to October 2011, cases from Department of Defense (DoD) components were allowed 30 days to submit fingerprints. The 14-day cutoff has long been the standard for all government agencies except DoD. The 14-day allotment is now being applied for everyone except for overseas investigations. Since the main reason for case rejection by OPM has been non-receipt of fingerprints, this reduction in the time allotted to submit them could increase the case the reject rate at OPM, which has varied from 4% to 8% over the past few years. However, after spiking over 8% in October 2011 OPM case rejection rates declined to 3% in February 2012.

The Defense Industrial Security Clearance Office (DISCO) now permits the submission of fingerprints via the Secure Web Fingerprint Transmission (SWFT) system prior to submission of the Standard Form (SF) 86, “Questionnaire for National Security Positions.” SWFT has also been modified to allow an organization to service submissions by other organizations. “This allows companies to share services, such as one company collecting fingerprint information for another company, thus assisting those having not yet acquired electronic fingerprint capability.”

Security Executive Agent Directive 1

This new issuance by the Director of National Intelligence (DNI) restates in one document all the authority granted to the DNI as the Security Executive Agent (SEA) by law and executive orders.

New SEA Website

An SEA website was recently launched and is accessible through the National Counterintelligence Executive (NCIX) homepage.

Interim Clearances

A concern was raised about the possible elimination of interim clearances when the new revised Federal Investigative Standards are implemented in December 2013.

DISCO/OPM Case Metrics

As of February 2012 DISCO had 13,310 investigations pending adjudication—a decline of about 31% since September 2011—and OPM had 31,193 pending investigations—an increase of about 8% since September 2011.

In December 2011 the average end-to-end processing time for the fastest 90% of initial industrial clearances was 60 days with Top Secret (TS) cases taking 108 days and Confidential/Secret cases taking 50 days. TS Periodic Reinvestigations took an average of 123 days.

Intelligence Community Industrial Case Metrics

For the first time in a NISPPAC report, information was provided regarding contractor clearance processing by Intelligence Community (IC) agencies. IC agencies conduct approximate 5.9% of the security clearance investigations and adjudications on federal contractor personnel. During the 1st quarter of FY2012, average end-to-end processing for the fastest 90% was 103 days for initial cases and 156 days for periodic reinvestigations. This is fairly close to the data reported by DISCO/OPM for TS clearances. IC cases are almost exclusively for clearances involving access to TS and Sensitive Compartment Information. Metrics were also reported for non-IC agencies with delegated authority to conduct their own investigations. These account for less than 1% of all federal security clearance investigations.

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William H. Henderson is a retired federal clearance investigator, President of Federal Clearance Assistance Service (FEDCAS), author of Security Clearance Manual, Issue Mitigation Handbook, and a regular contributor to ClearanceJobsBlog.com and ClearanceJobs.com.