STATEMENT OF
JANE CHAPPELL,
VICE PRESIDENT, GLOBAL INTELLIGENCE SOLUTIONS,
INTELLIGENCE, INFORMATION AND SERVICES,
RAYTHEON COMPANY
before the
UNITED STATES SENATE
SELECT COMMITTEE ON INTELLIGENCE
—
March 7, 2018

Chairman Burr, Vice Chairman Warner, Members of the Committee, I am
honored to represent Raytheon today before the Select Committee on
Intelligence.
Raytheon and our employees understand — and take very seriously —
our obligation to protect the Nation’s secrets. We submit to the same clearance
process that governs our Government and military partners, and we take the
same oath to protect the information entrusted to us. Our number one priority
every day is meeting the needs of our customers.
As Vice President of Raytheon’s Global Intelligence Solutions mission
area within our Intelligence, Information, and Services business, I navigate the
disruptions that backlogs in the security clearance process cause every day —
not just for Raytheon, our suppliers, and our industry peers, but ultimately for
the warfighters, intelligence officers, and homeland security officials who rely
on our products and services to protect the United States and our allies.
The magnitude of the backlog and associated delays speaks for itself. In
September of 2017, the National Background Investigations Bureau (NBIB) faced
a backlog of around 709,000 investigations. Delays in the initiation,
investigation, and adjudication process for both secret and top secret
clearances were two to three times longer than the timelines set by Congress in
the Intelligence Reform and Terrorism Prevention Act of 2004.
But what those numbers fail to capture are the real-world impacts of the
backlog. New careers are put on hold, top talent is lost to non-defense
industries, and programs that will provide critical warfighter capabilities are
delayed. And these impacts come with a real-world price tag, resulting in
otherwise-unnecessary increases in program costs and inefficient use of
taxpayer dollars.
We would gladly accept these costs if the clearance process delivered
significant improvements in the security of our Nation’s most sensitive
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information, facilities, and personnel. Unfortunately, we have seen little
evidence that the decades-old clearance process achieves that goal, especially
when considering the threat posed by trusted insiders to classified computer
networks. The modern threat environment can no longer be addressed using
outdated and infrequent security snapshots.
To address the costs of the backlog, we ask Congress and the Executive
Branch to implement fundamental reforms that streamline the clearance
process and increase our Nation’s security by leveraging advances in
technology.
The Backlog
Raytheon is a technology and innovation leader specializing in defense,
security, and civil markets throughout the world, and a world leader in
advanced cybersecurity solutions for both the public and private sector. We
have a workforce of approximately 64,000 employees, 68% of whom hold some
level of security clearance. As these numbers demonstrate, Raytheon’s ability to
meet the needs of our customers depends on both our ability to attract and
retain top talent, and our ability to get our employees the clearances needed to
do their jobs.
With current backlogs, we have nearly 4,300 employees awaiting
clearances, and almost 5,000 more awaiting the completion of a periodic
reinvestigation — almost 15% of our total workforce.
In 2017, the average length of time it took a Raytheon employee to get an
initial clearance was:
•
•
•
•

225 days for Confidential,
252 days for Secret,
500 days for Top Secret, and
328 days for Top Secret/Sensitive Compartmented Information
(TS/SCI).

Surprisingly, the timelines for periodic reinvestigations were even longer,
exceeding 615 days for a Top Secret clearance holder.
Our Missile Systems business has a rolling backlog of between 400 and
500 new hires who are unable to start their jobs because of delays in
processing their clearances. And in the business unit I oversee, almost 300
software and systems engineers are also waiting.
These candidates have high-demand technical skills. They are
enthusiastic about supporting our customers, and they meet the stringent pre2

qualifications we impose on anyone applying for a clearance. In short, they are
“unicorns.” We do what we can to keep them interested while they wait for their
clearance, but a candidate’s patience only lasts so long, especially when they
have other options.
The Job Market
To truly understand the impact of clearance delays on the defense
industry, you have to start with the job market. Our customers demand the
most advanced technologies that Raytheon and the defense industry can
produce — particularly on the most sensitive programs. This requires a
continuous and persistent effort to recruit and retain top technical talent. And,
our pool for positions requiring clearances is further restricted to U.S. citizens.
Faced with these customer requirements, the demand for cleared talent
has dramatically increased. Currently, more than 120,000 job openings in the
United States require a Secret clearance, and another 30,000 require a TS/SCI.
By our estimates, 480,000 people in the contractor community hold a
Secret clearance, and 446,000 hold a Top Secret clearance. But most of these
candidates are already employed, which means there are far more open roles
than cleared candidates to fill them. This has led to a dire imbalance in the
market for cleared talent. As a result, employers are paying cleared candidates
an extra 10-15% in base pay and sign-on bonuses that start at $15,000.
In the last few years, non-traditional commercial competitors have also
entered the market, driving these premiums to unprecedented levels. A recent
example of this involved an entry-level software engineer who left Raytheon
after receiving his TS/SCI clearance. A commercial competitor offered him a
$20,000 sign-on bonus, a 15% increase in base pay, a 20% annual performance
bonus, a $25,000 annual bonus for maintaining a TS/SCI clearance, and $20,000
in company stock.
And this offer was not a one-off. We often find ourselves choosing
between matching these lucrative competitive offers and losing our cleared
talent.
While preparing for this hearing, a Vice President from our missile
business recounted a disappointing story. While he was pumping gas, he
started a conversation with the gas station clerk, who turned out to be a recent
college graduate who had accepted an offer to join Raytheon pending the
outcome of his clearance. The candidate moved across the country to Tucson
for his new job, but as his start date at Raytheon was delayed by the clearance
process, he was forced to work at the gas station to make ends meet. While we
are certainly proud he was willing to wait for the job of his dreams, many other
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candidates are not as patient. And, when you add the pressing weight of college
debt and the desire to keep technical skills current, the impact of delays on new
college graduates is only amplified.
The impact of clearance delays is not confined to our highly-skilled
technical workforce. They also affect candidates who we would like to hire for
stable and well-paid manufacturing jobs. Many of these candidates come from
lower- or middle-class backgrounds, and they simply cannot afford to wait —
unemployed and without pay — for months while a clearance is received. Far
too often, these candidates will accept another job well before we are able to
bring them on following a months-long delay in the adjudication of even an
interim Secret clearance.
To avoid stories like this, Raytheon often starts employees before they
are cleared. They are assigned as much unclassified work as possible, but
certainly not the kind of work they joined the company for, or what we hired
them to do. And, while they wait, the associated overhead costs grow and grow.
These costs ultimately work their way back into our products and services,
eroding the buying power of our customers and delaying the delivery of critical
capabilities.
Our subcontractors — particularly small businesses that cannot shift
employees or other resources to manage their way through clearance delays —
are also affected by the backlog. Recently, Raytheon identified a small, veteranowned business to conduct a significant portion of the work on a sensitive
Intelligence Community system designed to automate analysis for new sensors.
After waiting through long delays to get their employees cleared, Raytheon was
forced to give the subcontract to an alternative source to prevent program
delays.
Even companies the size of Raytheon are not immune, and clearance
delays have had real effects on our programs. To avoid the program delays and
cost increases caused by the clearance backlog, we work diligently with our
customers to leverage our cleared workforce across multiple programs to cover
gaps.
These gap-filling personnel decisions — based primarily on clearance
status instead of qualifications — have career consequences for everyone
involved. High-performing employees can be stuck doing less important work,
and program managers have to stretch cleared talent to cover critical tasks
while the employee they need waits for a clearance.
Managing risk on our most sensitive compartmented programs or
“Special Access Programs” (SAPs) is even more complicated because of the
severe restrictions on the number of billets made available by the Government.
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These restrictions can delay and limit workforce management decisions, and
often prevent cross-pollination of lessons learned and efficiencies across our
program portfolio. And reciprocity issues can sometimes prevent an employee
with an active clearance at the same level needed on a different program from
transferring between contracts without an additional investigation or
adjudication.
These impacts negatively affect the lives of our employees, hinder
Raytheon’s ability to effectively manage complex programs vital to our national
security, and add unnecessary costs that ultimately burden our customer’s
budgets and American taxpayers.
The Process
Despite various amendments to laws and executive orders, the security
clearance process has gone largely unchanged since the 1940s. Applicants
submit their background information and federal investigators (either federal
employees or contractors) conduct an extensive investigation of the applicant.
Investigators operate on a five-tier system, with each successive tier
mandating a more thorough background investigation based on the level of
access granted. Tier 5 is reserved for the most sensitive access — to Sensitive
Compartmented Information and other highly sensitive information or
positions.
Periodic re-investigations are initiated, conducted, and adjudicated the
same way as the initial clearance, and are required every 5 years for a top secret
clearance, 10 years for a secret, and 15 years for confidential.
If the process looks complex on paper, I can assure you it is far worse in
practice.
The intelligence reform act required each federal department and agency
to honor the clearances of others (with certain limited exceptions) — a process
known as “reciprocity.”
In practice, agencies do not always honor the investigations or
adjudications of others. Some mandate differently tiered investigations for
different types of suitability and access determinations. Some mandate a
polygraph. If a polygraph is required, the scope can vary. Some agencies
mandate a polygraph every three years before a contractor can access sensitive
government systems — even if the contractor has an active TS/SCI clearance
that does not yet require a periodic reinvestigation. Some elements of larger
departments do not acknowledge clearances issued by components within the

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same department. And, when these differences arise, a new investigation is
often ordered and added to the backlog.
And recently, at least one of our customers has mandated a Secret-level
clearance for access to Unclassified/For Official Use Only (U/FOUO) material.
These additional applications also clog the clearance pipeline, and impede
clearance applications for individuals that require access to information that is
actually classified.
Though we have seen some progress on reciprocity — particularly across
the Intelligence Community — the Government continues to struggle with the
size and scope of the issue. From our standpoint, the theory of reciprocity
exists, but in reality, reciprocity is managed to different risk levels across
different agencies. Simply put, the reciprocity ideal is not a fully realized
practice. It is our understanding that Government-wide reciprocity standards
originally planned for September 2013 have yet to be issued, are continually
challenged with effective interagency coordination, and have no proposed
deadline for completion.
The Government has only recently begun to automate and streamline the
investigation process. In 2003, the Office of Personnel Management (OPM)
automated the collection of information needed for the initial clearance
application. Since then, OPM has made progress on a digitized SF-86 — the
form applicants submit to initiate a clearance investigation or periodic
reinvestigation — as well as other improvements to information collection and
adjudication. However, following the OPM data breaches in 2015, at least one
Intelligence Community agency stopped using these web-based tools. While
OPM’s overall efforts are steps in the right direction, none of them represent
the transformative change needed to reduce the current backlog and prevent
future delays.
Interim Reforms
The magnitude of the current backlog and associated clearance delays
demands immediate and aggressive interim actions. Raytheon supports the
Government’s efforts to add investigative resources and ease requirements for
periodic reinvestigations, and we also appreciate efforts to streamline the
application process, automate and digitize certain information collection,
provide for secure data storage, and improve other related processes.
Despite these improvements, at investigative resource levels NBIB has
identified as feasible, GAO indicates that a “healthy” backlog — around 180,000
pending investigations — would not be reached until fiscal year 2022 “at the
earliest.”

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As an interim measure, Raytheon encourages the Government to
reevaluate the “first-in/first-out” investigation approach and adopt a risk-based
method that would quickly adjudicate low-risk investigations and prioritize
mission-critical investigations. Higher-risk, time-consuming investigations
would be delayed until additional investigative resources were available.
Adjusting the periodic reinvestigations process will also free investigative
resources for initial reviews, but we urge the Government to reconcile the
current extensions with inconsistent recognition of “expired” clearances.
Despite a December 2016 Department of Defense (DoD) memorandum directing
otherwise, employees with current, valid investigations are being denied access
by some customers based on Government-directed delays to initiate a periodic
reinvestigation. These inconsistent decisions exacerbate the backlog with no
clear risk-based justification.
The Government should also consider recognizing background
investigations conducted by private sector employers as the basis for lower-risk
clearance and access determinations. Consistent with applicable laws, these
employment-related investigations often entail the collection and review of
publicly available and sensitive information on a candidate’s financial, criminal,
residency, military and educational records. These records serve as the
foundational components of all federal clearance investigations. If these
investigations met Government-established standards for rigor, the results
could serve as the basis for certain lower-risk clearance, access, or suitability
determinations by an adjudicating agency.
Additional resources and thoughtful adoption of low-risk interim
adjustments may marginally improve the current situation, but fundamental
reforms to the clearance process are essential. Without these foundational
efforts, inefficiencies will continue to frustrate progress with no real increase to
the security of the Government’s information, facilities, or personnel.
Fundamental Reforms
In 2006 — with a clearance backlog of 300,000 investigations — a
coalition of industry associations recommended a set of reforms known as the
“Four Ones” (https://www.itic.org/publicpolicy/SecurityClearanceReformCoalitionWhitePaper%28Final%292006.pdf and
https://oversight.house.gov/wpcontent/uploads/2017/10/ITAPS_Hodgkins_Testimony_Security-ClearanceInvestigations.pdf).
•

One Application — one standardized and digitized application for all
clearance determinations, updated continuously and stored securely,

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•
•

•

to form the “permanent digital record” for the initial and any
subsequent suitability, access, or clearance determinations.
One Investigation — enabling a dynamic, ongoing examination of
individual risk by implementing continuous evaluation.
One Adjudication — streamlining and standardizing the overly
complex adjudication system so that one agency’s clearance decision
is respected by other departments and agencies, promoting reciprocity
and efficiency.
One Clearance — recognized across the entire Government,
transferable from department-to-department, agency-to-agency, and
contract-to-contract.

More than a decade after they were first proposed, the “Four Ones”
continue to serve as a roadmap for needed reforms, and a reminder that
progress has fallen far short of expectations.
To make immediate progress, Raytheon encourages the Government to
prioritize and set incremental milestones for implementing Government-wide
reciprocity, continuous evaluation, and information technology reforms.
Information technology reforms that enable automated application
collection, incorporate new information derived from investigations or
continuous evaluation, and provide secure, cross-domain mechanisms for
accessing investigative information are vital to support each prong of the “Four
Ones.” Technology forms the basis for automated applications and the
establishment of a permanent, electronic investigative file. It underpins
continuous evaluation, and is necessary to provide the confidence departments
and agencies need to confidently implement Government-wide reciprocity.
We support the direction that the Department of Defense (DoD) and the
Office of Personnel Management (OPM) are taking to establish the National
Background Investigation System, but vigorous oversight and robust resources
will be required to address integration and security risks that the system must
overcome.
Effective implementation of a comprehensive continuous evaluation
program will help eliminate the need for time-based periodic reinvestigations
for all clearance holders, cutting the unnecessary costs incurred to fully
investigate even low-risk individuals. More importantly, we strongly believe that
this dynamic, ongoing approach to vetting will increase security and detect,
deter, and mitigate insider threats.
As currently constructed, the periodic reinvestigation system only
provides a risk snapshot for clearance holders when the initial investigation is
conducted and at prescribed 5-, 10-, or 15-year intervals. In the intervening
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periods, our Nation’s security relies upon self-reporting and serendipity to
identify risks.
Continuous evaluation fills this security gap, providing immediate
reporting on security threats and allowing agency security officials to make
real-time risk determinations. When necessary, these risks may be so significant
that immediate personnel action is required. Alternatively, the risks may call
for initiation of a risk-based, aperiodic reinvestigation. Any aperiodic
reinvestigation, based on the continuous collection of investigative data since
the initial clearance determination and informed by targeted investigations
associated with significant security concerns, could be conducted more
efficiently than the current process which basically recreates the initial
investigation.
I would be remiss if I did not underscore Raytheon’s belief that an
effective continuous evaluation system must be accompanied by robust user
activity monitoring (UAM) programs. With so much sensitive information
contained in our Government’s information technology systems, it is vital that
security officials be able to quickly identify inappropriate user activity on their
networks — both classified and unclassified. Context-aware UAM programs,
when combined with data from other continuous vetting sources, will enable
real-time, risk-based decision making about system users and clearance
holders.
One tool informs the other, and the combination promotes increased
privacy protections. Comprehensive, detailed monitoring of all users is
unwieldy, impractical, and invasive. Modern, analytics-enabled UAM allows
security officials to adjust the sensitivity of the tool based on the risk
associated with particular users. So, a clearance holder with security risks
identified in continuous evaluation could be more carefully monitored by UAM
when using Government systems. Users with low-risk activity on Government
systems may require less comprehensive continuous evaluation. The
combination promotes efficient targeting of investigative resources toward
higher risks, and protects the privacy interests of low-risk personnel or
contractors.
The electronic availability of secure, up-to-date investigative records,
clearance histories, and any security risks identified through continuous
evaluation and UAM, should make the implementation of reciprocity that much
easier. Agencies will be more willing to trust prior adjudications and will have
access to any intervening derogatory information — not to make independent
clearance decisions, but to promote a one-Government/one-individual approach
to the clearance process.

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Finally, I believe it is critical to note that sustained and relentless
leadership — from both Congress and the White House — will be crucial to
successfully implement reforms. Even the most well-intentioned reporting
requirements, working groups, and legislative deadlines have not, and will not,
outlast the fear of change or the comfort of the status quo.
The Committee’s investments of time and resources to effectively
implement this security framework will help eliminate the investigative
inefficiencies, duplication, and stove-piped decision making that hamstring the
current clearance system. They will promote the effective and dynamic
recruitment, retention, and deployment of Government employees and
contractors as dictated by skill and performance, not based merely on the
availability of a current clearance. And, critically, they will help close the
security gaps that threaten our Nation’s secrets and personnel.
Thank you for the opportunity to be here today, and I look forward to
answering any questions you may have.
**********

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