20 years of clearance reform: From intelligence reform to Trusted Workforce

The Intelligence Reform and Terrorism Prevention Act was signed on Dec. 17, 2004, and the landmark legislation was designed to reform intelligence processes and address gaps highlighted in the wake of the 9/11 terrorist attacks. 

But 20 years after the legislation was passed, the key security clearance reform issues included continue to be problematic today. 

Here are four key areas of clearance reform issues we continue to talk about:

Timeliness: Security clearance processing times are an issue that just won’t go away. IRTPA mandated that 90% of all clearances should be completed within an average of 60 days. Somewhere along the way, that benchmark shifted to 80 days for Top Secret clearances and 40 days for Secret clearances. 

But as of the fourth quarter of FY2024, we’re far from meeting even those adjusted targets. The average time to process 90% of Top Secret clearances stands at 169 days, while Secret clearances take an average of 68 days. These delays ripple through national security operations and talent retention. Interim clearances can save the day for Defense Department applicants, but because they’re not used in the IC, onboarding timelines for national security careers remain an issue to accomplishing the mission.

Single Investigative Agency: Here’s some history—before December 2004, Defense Security Service personnel performed clearance investigative work using the Office of Personnel Management’s systems. In February 2005, DSS investigators officially moved to OPM. At that time, OPM handled 95% of federal background investigations, with a small fraction left to a dozen or so other agencies. 

Fast forward to today: the Defense Counterintelligence and Security Agency has taken OPM’s place as the lead agency, conducting that same 95% of investigations, with the remaining agencies still handling a small slice of the pie. Today we’re closer to a single investigative agency with DOD taking over both the technology and the investigation missions. It’s another reason why the success of the National Background Investigation Services is so important. 

Which segueways us into our next security clearance reform initiative -

Single Clearance Database: Despite years of talk, NBIS remains a fragmented system of systems. With new oversight and accountability, there is hope that NBIS may finally be getting its sea legs – but it’s a critically important mission and it will take all hands on deck to ensure DCSA can get the job done. 

Clearance Reciprocity: There’s been some progress in reciprocity, but that progress has largely been a one-way street – for applicants entering into DOD from other agencies. Reciprocity into the IC remains an issue, with SCI and special access programs making the process more complex. The Government Accountability Office has highlighted how this is an issue: federal agencies simply don’t trust each other and their investigative processes. This undermines mobility for cleared personnel and slows down mission-critical operations.

That’s the depressing news – when it comes to the major muscle movements of clearance reform, we have been talking about the same issues for two decades. It’s an issue that spans generations and administrations. But, here’s the good news. IRTPA was the single largest security clearance reform effort – until Trusted Workforce 2.0. 

Trusted Workforce 2.0 is the most extensive and transformative initiative in the history of U.S. security clearance policy. And unlike IRTPA which attempted to create benchmarks and accountability, TW 2.0 marked the first policy overhaul of the reform effort since the 1950s. Its emphasis on modernization, technology, and policy standardization sets it apart from any prior effort and has the possibility of addressing each of the four issues that have been reform priorities since IRTPA (emphasis on possibility – this is a work in progress).

With more than 40 policies updated in the past several years and a new administration set to take leadership, now is the time to continue to put extra gas in the tank to ensure we’re not just talking about failed reform 20 years from today but marking progress. Steps to ensure we’re doing it include:

Accountability Around Implementation: Forty policies have been updated – but it’s up to the individual agencies running security programs to actually implement those policies. Streamlined communication and continued prioritization of the security clearance process by Congress will be important to ensuring security clearance reform isn’t just policy – it’s practice. And we need to keep the Performance Accountability Council Program Management Office pushing that policy forward and educating agencies and contractors on implementation.

Streamlining Processes and Harnessing Technology: Security clearance processing times are unacceptably slow. And the process is unacceptably obtuse. Applicants are often left with little to no clue about where they stand in the process. The government can do better. We need to prioritize implementation of the Personnel Vetting Questionnaire, which will streamline the onboarding process. And work toward NBIS components that enable applicants to gather basic information about the process. If NBIS can’t do it, it’s time to enable the IT systems that can. The fact that bemoaning security clearance processing times has been a topic for 20 years points to systemic issues. Trusted Workforce can streamline processes, but that won’t happen if individual agencies set up roadblocks or fail to implement new technologies. 

Increasing Workforce Size and Mobility: We talk often about the size of the cleared workforce – and it’s typically someone bemoaning the number of people with security clearances in the wake of the latest breach. Contract requirements place constraints on the number of qualified workers in the talent pool, in a talent pool that is already constrained. Security clearance reform has for too long focused on reducing the number of individuals with access to classified information while taking no steps to reduce the deluge of classified information created. The costs of maintaining classified information remain difficult, and lack of agency consistency in how figures are reported is something highlighted by the Information Security Oversight Office. The threats aren’t shrinking. And neither should the workforce addressing them without better data to demonstrate how we’re also reducing the amount of classified info we create, and not just the workforce that supports it. 

Some missions are so important and complex they’re always under construction – the security clearance process may be one of those. But there are plenty of new problems to solve. Let’s start fixing the ones we’ve known about for far too long so we can keep innovating and improving – not sitting stuck in the way back machine of clearance reform.