BlackLeafwatch the watchmen
DOD/DCSA personnel vetting reform and NBIS system development

DOD's $4.6B background-check system hasn't made clearances faster

Summary

Since 2018, the federal government has been trying to fix its notoriously slow security-clearance process through a reform called Trusted Workforce 2.0 -- and the IT system meant to carry that reform, DOD's National Background Investigation Services (NBIS), has been in development since 2016. Two GAO reports, about 9.5 months apart, show the reform from two angles that land on the same conclusion. In May 2025, GAO surveyed 45 agencies and 626 contractors and found the reform's benefits mixed at best, with IT problems as the top complaint. In February 2026, GAO found DOD's NBIS cost estimate finally reliable for the first time -- but the schedule still isn't, the reform's own deadline has slipped two years, and the clearances everyone is waiting on are taking longer, not less.

By Marcus Aurelius · July 12, 2026

Security clearance delays landed personnel vetting on 's High-Risk List in 2018, the same year the government launched Trusted Workforce 2.0 to fix it. The reform depends on a single IT system, 's National Background Investigation Services (NBIS), that has been in development since 2016. In May 2025, surveyed federal agencies and contractors on how the reform was actually going. In February 2026 -- about 9.5 months later -- testified on the system underneath it, and the two findings point the same direction.

A background-check system years behind its own schedule

originally expected NBIS -- which handles background investigations for most federal agencies and more than 13,000 contractor organizations -- to be complete in 2019. Instead, after missing repeated targets, 's Defense Counterintelligence and Security Agency (DCSA) paused development in 2024 to revise its approach; the program's long-term goal is now to finish by the end of fiscal 2027. has spent $2.4 billion on NBIS and legacy systems through fiscal 2024, and projects $2.2 billion more through fiscal 2031 -- $4.6 billion total. 's 2025 assessment found that cost estimate reliable for the first time, meeting or substantially meeting all four best-practice characteristics. The schedule is a different story: it substantially met two of the four reliability characteristics but only partially met the other two -- DCSA still hasn't identified a critical path for the program or conducted a schedule risk analysis, the tools that would show which delays actually threaten the 2027 target.

A $4.6 billion system, most of it already spent
DOD spending on the NBIS background-investigation IT system
Spent through FY2024
2.4
Projected, FY2025-2031
2.2
Source: GAO-26-108838
View data as table
DOD spending on the National Background Investigation Services (NBIS) IT system and legacy systems: amount spent through fiscal year 2024 versus projected additional spending through fiscal year 2031
Spent through FY20242.4
Projected, FY2025-20312.2

The reform the system is supposed to carry keeps slipping too

When the government's Performance Accountability Council launched Trusted Workforce 2.0 in 2018, it planned to finish by the end of fiscal 2026. NBIS delays and other factors have pushed that to fiscal 2028 -- and the slide continues: at least 46% of the NBIS-related milestones in the reform's own January 2026 strategy update have been pushed out just since April 2025.

None of this is making clearances faster

The reason any of this matters is what it's supposed to fix. As of the second quarter of fiscal 2025, agencies took an average of 206 days to complete the fastest 90% of initial Top Secret clearances -- 92 days beyond the government's own 114-day goal, and about 81% longer. That average has trended longer, not shorter, from fiscal 2022 through fiscal 2025, and agencies haven't met timeliness goals for the investigative phase of initial Secret and Top Secret clearances since 2021.

Clearances are taking far longer than the government's own goal
Average days to complete the fastest 90% of initial Top Secret clearances, Q2 FY2025
Government-wide goal
114
Actual, Q2 FY2025
206
Source: GAO-26-108838
View data as table
Average days to complete the fastest 90 percent of initial Top Secret security clearances, government-wide goal versus actual performance as of the second quarter of fiscal year 2025
Government-wide goal114
Actual, Q2 FY2025206

Continuous vetting -- the ongoing automated record checks meant to replace periodic reinvestigations -- depends on NBIS too, and in the meantime agencies are running it on legacy systems that haven't been modernized. The volume of alerts those systems generate for review has more than tripled, from about 30,000 per quarter in fiscal 2023 to over 100,000 by the third quarter of fiscal 2025. A third of the agencies surveyed in May 2025 said NBIS delays had already disrupted their continuous-vetting rollout.

Continuous-vetting alerts have more than tripled
Continuous-vetting alerts requiring review, per quarter
FY2023 (per quarter)
30,000
Q3 FY2025
100,000
Source: GAO-26-108838
View data as table
Volume of continuous-vetting alerts requiring review, per quarter: fiscal year 2023 versus the third quarter of fiscal year 2025
FY2023 (per quarter)30,000
Q3 FY2025100,000

Agencies and contractors feel it too

's May 2025 survey of 45 agencies and 626 contractors found the reform's benefits real but uneven. About 98% of agencies said adapting their IT systems to the reform's requirements had been at least somewhat challenging, and only about 51% said their ability to manage onboarding risk had improved -- the rest reported no change, a decline, or no basis to judge. Contractors were similarly split: about 45% said their risk-management ability hadn't changed at all, versus about 22% who said it had improved. made two recommendations to in its February 2026 testimony, both aimed at fixing the NBIS schedule's remaining gaps; provided technical comments but did not record a formal concurrence with either.

Total DOD spending on the NBIS background-check system, through FY2031
$4.6B
$2.4 billion already spent through FY2024, plus $2.2 billion more projected -- for a system DOD originally expected to finish in 2019
Longer than its own goal that fastest-track Top Secret clearances now take
+81%
206 days actual versus a 114-day goal, as of Q2 FY2025 -- and trending longer, not shorter, since FY2022
Years the Trusted Workforce 2.0 reform's own completion deadline has slipped
2
from fiscal 2026 to fiscal 2028 -- with at least 46% of the NBIS milestones behind that reform pushed out just since April 2025

The takeaway

  • A reliable cost estimate isn't the same as a reliable program. called 's 2025 NBIS cost estimate reliable for the first time, but the schedule behind that same $4.6 billion system still lacks a critical path or a risk analysis -- the tools that would show whether the fiscal 2027 target is realistic.
  • The reform's own deadline keeps moving, and the slide is accelerating. Trusted Workforce 2.0's target has already slipped two years, from fiscal 2026 to fiscal 2028, and at least 46% of the milestones behind it moved again in less than a year.
  • The thing this is all meant to fix -- clearance speed -- is getting worse, not better. The fastest 90% of initial Top Secret clearances now take 81% longer than the government's own goal, and says that average has trended longer, not shorter, from fiscal 2022 through fiscal 2025.

Findings on agency and contractor experience implementing Trusted Workforce 2.0 are from -25-107325, 'Federal Workforce: Observations on the Implementation of the Trusted Workforce 2.0 Personnel Vetting Reform Initiative' (May 9, 2025), read directly in full via an archived copy after the current gao.gov asset URL blocked direct access. Findings on the NBIS cost estimate, schedule, and clearance-timeliness data are from -26-108838, 'Personnel Vetting: Leadership Attention Needed to Prioritize System Development and Achieve Reforms' (February 24, 2026), read directly in full. The two reports examine the same reform effort about 9.5 months apart -- the first from the field (agencies and contractors living with it), the second from the system-engineering side (the IT program the whole reform depends on).

Sources(2) ▾
  • U.S. Government Accountability Office, Federal Workforce: Observations on the Implementation of the Trusted Workforce 2.0 Personnel Vetting Reform Initiative (2025-05-09)-25-107325, a report to congressional committees (mandated by the FY2024 NDAA's biennial-survey requirement through 2029) presenting 's survey of 45 federal agencies and 626 federal contractors on their experience implementing the Trusted Workforce 2.0 personnel-vetting reform -- the field-experience facet. Distinct from doc-gao26-108838 (the underlying NBIS IT-system cost/schedule facet, published about 9.5 months later). Direct gao.gov PDF fetch returns HTTP 403; fetched via an existing Wayback capture. gao.gov · original document
  • U.S. Government Accountability Office, Personnel Vetting: Leadership Attention Needed to Prioritize System Development and Achieve Reforms (2026-02-24)-26-108838, testimony of Alissa H. Czyz before the House Oversight Subcommittee on Government Operations, assessing 's 2025 cost estimate and schedule for the National Background Investigation Services (NBIS) IT system and its centrality to Trusted Workforce 2.0 reform. Published about 9.5 months after doc-gao25-107325, converging on the same conclusion from the system-engineering side. Fetched directly from files.gao.gov (HTTP 200); direct gao.gov PDF asset returns HTTP 403. gao.gov · original document
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