Ask any background investigator, and they’ll tell you there’s a compelling need for major changes to the way the field component of Personnel Security Investigations (PSIs) is staffed, organized and managed.  Efforts to improve federal PSIs have focused primarily on investigative scope1 and methodology (automated or manual).  I believe the deficiencies in the organizational structure and work culture that negatively affect the people who conduct field investigations have been largely ignored.

Prior to 1972 there were four major entities conducting PSIs—Army, Navy, Air Force, and the Office of Personnel Management (OPM).  Each had its own network of regional offices, field offices (FOs), and resident agencies (RAs) across the United States.  In 1972 Army, Navy, and Air Force investigators were transferred to the newly formed Defense Investigative Service (DIS), leaving only DIS and OPM to conduct about 98 percent of all federal PSIs.  The creation of DIS eliminated redundancy, centralized control of PSIs, and provided greater economy of scale for DOD.  Eventually DIS grew to about 215 investigative offices and 2,500 investigators.  In the 1990’s most of OPM’s PSI function was privatized, and DIS was downsized.   DIS regions were reduced from eight to five and many FOs and all the RAs were closed.2  More than 200 first-line supervisor positions were eliminated.  By 2005 when the Defense Security Service (formerly DIS) transferred its investigative staff to OPM, the majority of its 1,250 field investigators worked from their homes.

OPM and Outsourcing

Today OPM conducts 95 percent of all PSIs for the federal government; however, they use three separate entities to perform field investigations—one federal workforce and two private companies.  There are a few other private companies working as Investigation Service Providers (ISPs) for approximately eight of the ten federal agencies that control their own PSIs.  State Department and FBI operate differently; they centrally control their PSIs and contract directly with scores of individual investigators across the U.S. to do their field work.

Most personnel security investigators (federal employees and contractors) work from their homes and rarely have face to face contact with their supervisors or other investigators.  Supervisory span of control can be as high as 30:1.  Some investigators have “case managers” rather than supervisors.  Some supervisors are only concerned with an investigator’s “overdue list” and their weekly productivity reports—the responsibility for reviewing the investigator’s reports is left to someone else.  Hiring, training, supervising, and motivating new investigators has sunk to an all-time low.  Too often new investigators are turned loose with credentials, a car, a notebook computer, and a caseload to work from their homes soon after completing a basic investigator course.  Rather than cultivating competent investigators, who can ferret out the relevant information needed by adjudicators, their jobs have been reduced to verifying information.  They’re forced to use long detailed checklists and slavishly comply with one-size-fits-all instructions that often border on the absurd.  To become an effective investigator, new, inexperienced personnel need months of on-the-job training and additional months of mentoring.  Their case work needs to be thoroughly reviewed for at least two years by an experienced supervisor who understands the geographic area where their work is being done.

Technology Doesn’t Trump Field Work

Increased reliance is being placed on technology to do a significant portion of the checks required in a PSI.  Automated systems, using computer accessible sources of information, have a tremendous potential for finding derogatory and/or anomalous information that can be used to flag a case for an “Expandable Focused Investigation” (EFI), but the information from automated checks alone cannot be used to deny or revoke a clearance.  A flagged case has to be turned over to a field investigator for additional record checks and interviews to fully develop all relevant information and to give the applicant a chance to respond to it.

Field investigators will also be needed to do some standard interviews and record checks for the highest level clearances, but a greater portion of their time will be spent investigating the cases flagged by automated checks for an EFI.  These will be the cases where the quality of the investigation is critical—the cases involving people like Manning, Snowden, and Alexis.   These cases will require real investigators, not information verifiers.

For most investigators to do quality work, they need a supportive organizational structure and culture that facilitates and emphasizes quality.  Most need an office where they can interact with other investigators, exchange information, listen to war stories, blow off steam, and consult in person with their supervisor.  The benefits of work-related social interaction shouldn’t be ignored.

One Solution: Single Sourcing

I believe we need a single Government entity that will do 100 percent of all federal PSIs (including polygraph) without outsourcing any of its work to private companies.  For the moment let’s call it the National Investigative Service Agency (NISA).  Individual contract investigators would comprise about 20 to 40 percent of its workforce.  This will allow NISA to expand and contract with changes in its caseload.  Contract investigators would work directly for NISA under the control of local NISA supervisors.  This will create a greater economy of scale and will reduce or eliminate duplication of effort .

NISA would need 200 to 300 FOs and RAs geographically located so that at least 80 percent of the workforce could easily commute to an office.  NISA first-line supervisor would be responsible for a combination of no more than 11 employees and contractors.  These supervisors would assign and review all case work and act as the Contracting Officer’s Representative (COR) for the contract investigators.

This organizational model existed at DIS for a short time in the 1990’s, but the use of contractors in this manner was never fully embraced by DIS management, and there were funding problems.3  DIS was an appropriated fund activity, and it staunchly resisted converting to a “fee-for-service” model like OPM.  This ultimately led to its demise.  DIS had no control over the number of investigations it was tasked to complete with the fixed amount of money it was given each year.

A single investigative entity—operating on a fee-for-service basis, staffed primarily with federal employees, and augmented with individual contract investigators—conducting all federal PSIs has the greatest potential to maximize investigative quality, quantity, and timeliness and keep all investigative work fully under the control of a federal agency.

Improving Investigations and the OPM Breach

Reports resulting from the September 2013 Washington Navy Yard Shooting caused the Government to complete two studies regarding how PSIs should be managed.  One study was to determine whether PSIs “should be an inherently governmental function, and if not, whether it could be performed by a non-profit, private sector corporation. . . .”  The other was to determine whether the current DOD approach for obtaining PSIs from OPM is the most efficient and effective approach.   It should be noted that DOD accounts for about 80 percent of OPM’s investigative workload.

Both of these studies may have been overtaken by events.  A recently completed 90-day Government review of the OPM data breach (in which over 20 million security clearance records were compromised) has resulted in a recommendation to create a new investigative agency and transfer the responsibility for PSIs from OPM to the new agency.   I hope the people responsible for standing up this new agency understand how field investigations need to be staffed, organized and managed and don’t just import the existing structure from OPM.

1  Scope refers to the number and type of investigative actions (e.g. education record checks, employment reference interviews, police record checks, credit check, etc.)

2  FOs were headed by a Special Agent In Charge (SAIC), had more than 10 investigators, and often had one or more subordinate RAs.  RAs were headed by a Senior Resident Agent (SRA) and had less than 10 investigators.

3  I managed a DIS FO in the 1990s that had federal investigators, contract investigators, and a subordinate RA.

 

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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 and Issue Mitigation Handbook, and a regular contributor to ClearanceJobsBlog.com and ClearanceJobs.com.