The government is very good at self reflection. Positive action is a little more difficult. A Government Accountability Office report released today provided an overview of the Personnel Security Program, the status of the security clearance backlog, and a review of the changes in the security clearance process from the years 2012 to 2016. Its first appendix may provide the biggest nugget into how we arrived at the problems we’re in today – since May of 2009, GAO has made 37 recommendations to executive branch agencies related to improving the personnel security process. As of November 2017, agencies had implemented 12 of those recommendations.
Obviously, not every recommendation, even from the GAO, needs to be done. But the fact that the personnel security program is bogged down in delays and backlogs (again) makes it clear there is more to be done in the security clearance reform effort – and government agencies are not doing it.
The report highlighted the steps the National Background Investigations Bureau (NBIB) has taken to improve the personnel security process, but noted it faces operational challenges that affect its ability to reduce the backlog and increase the number of investigators doing the work.
The Problem with Backlogs and Delays
The GAO report notes the current backlog and 459 day average wait for a top secret security clearance as of 2016 aren’t victimless issues – they’re matters of national security and financial responsibility.
“Problems related to backlogs and the resulting delays in determining clearance eligibility and issuing initial clearances can result in millions of dollars of additional costs to the federal government, longer periods of time needed to complete national security related contracts, lost opportunity costs if prospective employees decide to work elsewhere rather than wait to get a clearance, and diminishing quality of the work because industrial contractors may be performing government contracts with personnel who have the necessary security clearances but are not the most experienced and best-qualified personnel for the positions involved,” the report warns.
NBIB has been working to address the backlog, but it’s trying to improve business processes while it also battles to attract and maintain a quality workforce – without a clear strategic plan to address those personnel challenges, according to the GAO. NBIB had a vacancy rate of about 17 percent in its field operations department as of July 2017. That includes the federal investigator staff. NBIB assumes it will have 277 vacancies within its federal investigator workforce at any given time, due to high attrition rates. The inability to retain a quality workforce also means it’s unable to project workforce figures past April 2018.
Where NBIB has seen some progress is within reengineering its business processes to emphasize quality and completeness. A business process evaluation identified 57 challenges within the personnel security process. NBIB developed automation and digitization initiatives to improve the quality of information it receives at the start of the investigation process, which will reduce the investigation level of effort required to correct incorrect data.
A government agency by another name is not as sweet
A common criticism of NBIB is that it is simply the former Federal Investigative Service by another name. The GAO report highlighted some of the differences between the agencies including within structure. NBIB created four new departments that didn’t exist under FIS, including:
- Federal Investigative Records Enterprise. The functions of this department include a new law enforcement and records outreach group to improve outreach and more effectively collect information with state and local law enforcement offices.
- Policy, Strategy and Business Transformation. The functions of this department include expanding existing performance reporting to incorporate metrics regarding effectiveness; and researching and identifying systemic issues in workload, processes, and products to determine where process improvement could be achieved.
- Contracting and Business Solutions. The functions of this department include enhancing and consolidating administration of NBIB contracts to provide consistent oversight.
- Information Technology Management Office. The functions of this department include supporting the delivery and enhancement of quality IT systems to NBIB in a timely and effective manner, gathering and communicating needs and requirements for new applications, and coordinating implementation of changes to current systems.
A ‘Field Contracts’ division was also put in place to oversee the contract workforce. Contractors perform approximately 60 percent of NBIB’s background investigations work, according to the report, and since 2014 federal employees have reviewed all background investigation reports produced by contractors. The quality reviews are helping to increase the quality of investigations, the report indicates. The percentage of cases conducted by contractors which require additional work after submission decreased from 6 percent in 2014 to 3.2 percent in 2014.
The history of personnel security clearance reform
The crux of the GAO report is that the current backlog and processing delay issues aren’t an NBIB problem, or a workforce problem – they’re a systemic problem. The fever pitch of reform interest has been quantified in congressional hearings, interagency reviews, and policy recommendations. Those recommendations have rarely, if ever, translated to actual reform.
- In response to the September 2013 shooting at the Washington Navy Yard, the Presidential Advisory Committee conducted a 120-day interagency review to assess risks in the security clearance process.
- A February 2014 report made 37 recommendations to improve the clearance process, including improving data sharing, and improved reporting measures. Only 12 of those recommendations have been made.
- In March 2014, OMB established Insider Threat and Security Clearance Reform as a cross agency priority goal. Agencies were to work together to ensure investigations and adjudications meet government-wide standards.
- In response to the OPM data breach, in 2015 the PAC conducted a second 90-day review of the government security clearance process.
- The report recommended four actions to improve the background investigations process and infrastructure. It also recommended the creation of the NBIB and the Department of Defense’s role in overseeing personnel security IT systems.
- In 2012 updated Federal Investigative Standards were approved. Security Executive Agent Directive 4 and its updated adjudicative criteria weren’t implemented until June of 2017. From initial proposal to implementation, this relatively minor change in the adjudicative criteria took nearly 10 years.
The latest GAO personnel security recommendations
The latest iteration of the GAO’s efforts to make improvements to the security clearance process resulted in six recommendations, three to ODNI and three to NBIB.
ODNI GAO Report Recomendations:
- Establish a milestone for the completion of government-wide performance measures for the quality of investigations;
- Conduct an evidence-based review of the investigation and adjudication timeliness objectives for completing the fastest 90 percent of initial secret and initial top secret security clearances, and take action to adjust the objectives if appropriate;
- develop a government-wide plan, including goals and interim milestones, to meet those timeliness objectives for initial personnel security clearance investigations and adjudications.
NBIB GAO Report Recommendations:
- Develop a plan, including goals and milestones, that includes a determination of the effect of the business process reengineering efforts for reducing the backlog to a “healthy” inventory of work, representing approximately 6 weeks of work.
- Establish goals for increasing total investigator capacity—federal employees and contractor personnel—in accordance with the plan for reducing the backlog of investigations.
- The Director of NBIB should build upon NBIB’s current workforce planning efforts by developing and implementing a comprehensive strategic workforce plan that focuses on what workforce and organizational needs and changes will enable the bureau to meet the current and future demand for its services.
The problems with the current personnel security process have been a decade in the making. While it’s easy to look at the years-long delays and 700,00 case backlog and wonder how we got here, the GAO report makes it clear – today’s delays were born or amplified through yesterday’s policy problems.