To protect sensitive information, certain positions in the federal government require candidates to obtain and maintain a security clearance. Security clearances help ensure that an individual is trustworthy and capable of handling sensitive information, which has the potential of harming the United States if divulged. From 2014 to 2018, the backlog of investigations increased from approximately 190,000 to 710,000. A candidate can expect to wait for a fully adjudicated Secret clearance between 153–197 days while the wait for a Top Secret clearance is between 134 to 395 days. This wait time is considered the current norm; however, the guidelines in the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) set performance measures of 60 days to complete investigations and adjudicate security clearances.
Literature in the fields of information security, personnel security, risk management, and organizational change form the basis for the theoretical concepts that may improve the security clearance process in the United States. Legal authorities, expert testimony, and government reports relating to the security clearance process in the United States serve as a guide to determine what measures are legally required for government departments and agencies to ensure the integrity of sensitive information, as well as establish metrics for government performance. The security clearance process in the United States was analyzed with these factors in mind to determine whether changes in policies and procedures might improve the timeliness of security clearance background investigations and adjudications while recruiting and maintaining trustworthy personnel.
A policy options analysis was conducted to evaluate potential improvements to the security clearance process. Policy recommendations focused on the incorporation of two specific Government Accountability Office recommendations, the investigation backlog and investigator capacity, in addition to novel criteria that considers foundational concepts in information security, risk management, and organizational change. Policy options included maintaining the current system while adding annual continuous evaluation, hiring additional National Background Investigations Bureau (NBIB) investigators to reduce the security clearance backlog, and limiting the clearance population to NBIB investigator throughput.
A cost-benefit analysis was developed for each policy option that depicted the notional process along with associated risks and opportunities, and assumptions for the implementation of each policy. The proposed policies were evaluated for improvements to the security clearance investigation quality, increased timeliness to the security clearance investigation process, and potential cost increases or decreases to security clearance investigations. An alternate solution matrix was created to synthesize the positives and negatives of each policy recommendation.
Policy options employed either a developmental, transitional, or transformational approach to organizational change. Developmental change is notionally the least amount of difficult change, while transitional change is notionally a moderate organizational change and transformational change is notionally the most difficult organizational change. Presently, the NBIB is responsible for approximately 90 percent of the security clearance background investigation workload. Policies suggested are for the use and consideration of the NBIB. It should be noted that with the looming reorganization of the NBIB, and the transferring of background investigation roles and responsibilities back to the Department of Defense for their staff, these policy suggestions and approaches would only be altered slightly, but still recommended regardless of the reorganization status due to the large challenge that the security clearance backlog poses. For the purposes of the following recommendations, the author assumed that the NBIB would still maintain its current role and share of the investigation burden.
A. DEVELOPMENTAL APPROACH—ADDING ANNUAL CONTINUOUS EVALUATION TO THE CURRENT SECURITY CLEARANCE PROCESS
The developmental approach to changing how the NBIB currently conducts background investigations consists of adding a requirement to run national agency checks on holders of security clearances annually. This approach expands on how the NBIB currently conducts investigations by validating that users who have access to sensitive information are trustworthy by increasing the frequency of individual reinvestigation to allow more frequent checks for indicators of maladaptive behaviors. By increasing the frequency of reinvestigation across the security clearance population, information security has a higher likelihood of being protected from insider threat due to this increase in the quality of the investigation. This approach, however, would not reduce the security clearance backlog, nor would it reduce costs associated with background investigations since more time and money would be required to process more frequent reinvestigations across the security clearance population.
B. TRANSITIONAL APPROACH—HIRING ADDITIONAL BACKGROUND INVESTIGATORS
The transitional approach to organizational change within the NBIB focuses on increasing investigator capacity by hiring additional investigators. This approach would bring the NBIB into an environment where they would be able to meet the current demands for security clearance investigations, make improvements in information security, investigation quality, and reduce the security clearance backlog. With investigators having more time to focus on a lesser workload, the quality of investigations would increase. Since more time could be spent per investigation, theoretically, the individuals being granted security clearances would have a higher likelihood that their investigations were not rushed, and therefore, would be trustworthy with sensitive information and thus make positive gains in increasing information security. This approach would also result in an increase in cost to the security clearance process, since the NBIB would have to increase its staff from 7,2000 to approximately 29,000 to reduce the security clearance backlog.
C. TRANSFORMATIONAL APPROACH—LIMITING ANNUAL INVESTIGATIONS TO NBIB THROUGHPUT
Limiting the annual security clearance investigations to the throughput that the NBIB could still manage to conduct quality investigations would transform the operating environment for the NBIB, as well as for departments and agencies that rely on the NBIB for investigation support.
Since the ideal caseload for the current staff of NBIB investigators is between 160,000–180,000 investigation products per year to include novel investigations and reinvestigations, this suggested policy will limit the amount of novel clearances and reinvestigations completed on an annual basis until the security clearance backlog is cleared.
This approach would reduce the backlog of security clearances over time, improve information security, and increase the quality of background investigations by allowing more time per investigation product for the current NBIB investigator staff. This approach would not result in cost increases to the security clearance process since no new staff or technology would be required to implement it.
The following table shows that the transformational approach may notionally result in the most improvements. Limiting the number of investigations and reinvestigations to NBIB investigation throughput can possibly reduce the security clearance investigation backlog, increase the quality of investigations, as well as increase information security.
Does policy reduce security clearance investigation backlog? If so add 1 point. Does policy improve information security? If so add 1 point. Does policy increase potential costs to security clearance process? If so, subtract 1 point. Does policy increase quality of investigation? If so add 1 point. Total
Adding Annual Continuous Evaluation to the Current Security Clearance Process +/-0 +1 +/-0 +1 2
Hire Additional Background Investigators +1 +/-0 -1 +1 2
Reduce Clearance Population to Investigator Throughput +1 +1 +/-0 +1 3
Based on the analysis, limiting the clearance population to the background investigator throughput achieves the best total positive outcome in the security clearance process. This policy option decreases the backlog by reducing the demand of investigations on security clearance investigators. Positive outcomes are gained in the quality of investigation by allowing investigators to take more time on their investigation products since they will have a sharply decreased caseload. This policy option also has the potential to improve information security by decreasing the number of individuals with access to classified information; the fewer individuals with access, the lower the chances are for system breaches by insider threat.
The challenge to this transformational approach in addressing this problem is that the potential capacity of work in the homeland defense and national security space becomes limited. Cutting the number of individuals supporting homeland security and national defense missions without a phased approach could result in inadequate staffing to complete related missions. The limitation to fixing the number of cleared population to investigator capacity is that a significant amount of time would be required to develop staffing and workload transition plans to adapt to this new environment.
A potential also exists for a limited capability of staff to share sensitive and classified information between the interagency. While reducing the population with security clearances helps reduce the amount of threats that can impact sensitive information, it may limit the ability of the U.S. government to complete its national defense and homeland security mission.