24-E-0020
February 8, 2024

At a Glance

The EPA's Enhanced Personnel Security Program Is on Track,
but Challenges to Full Implementation Remain

Why We Did This Evaluation

To accomplish this objective:

The U.S. Environmental Protection
Agency Office of Inspector General
conducted this evaluation to determine
the EPA Personnel Security Branch's
progress in implementing a fair and
effective enhanced personnel security
program in accordance with the
director of National Intelligence's
performance standards.

Executive Order 13467 requires all
executive branch agencies to
implement reforms to enhance their
personnel security programs. These
reforms are intended to establish a
single vetting system for the federal
government. For this evaluation, we
assessed "fairness" and "effectiveness"
as the extent to which the EPA is on
track to achieve full implementation of
the enhanced personnel security
program by established milestones and
is compliant with the applicable policies
and guidance.

To support these EPA mission-
related efforts:

•	Compliance with the law.

•	Operating efficiently and
effectively.

To address this top EPA
management challenge:

•	Managing grants, contracts, and
data systems.

What We Found

As of October 2023, the EPA's Personnel Security Branch, or PSB, has successfully met all
milestones and requirements to date to fairly and effectively implement the director of
National Intelligence's enhanced personnel security program, known as the Trusted
Workforce, orTW, Program. Specifically, the PSB has completed the first two of the
program's three implementation steps, referred to as TW 1.25, TW 1.5, and TW 2.0. The
final step, TW2.0, must be completed by March 30, 2026, and will culminate in full
implementation of the program. As of October 2023, the PSB is on track to meet full TW 2.0
implementation. To prepare for full implementation, the PSB has already adopted all
applicable Office of the Director of National Intelligence policies, procedures, and controls.

The TW Program is designed to provide a continuous vetting environment that allows the
PSB to track any risks to personnel security in real time. The PSB's most significant
remaining challenge is ensuring that there is sufficient capacity to meet the full TW 2.0
continuous vetting requirements by the March 30, 2026 milestone. As of October 2023, the
PSB had eight staff to implement the TW 1.5 requirements to provide continuous vetting
services for the approximately 1,100 EPA employees classified as the Agency's national
security population. Full TW2.0 implementation will require continuous vetting services for
the entire population of EPA employees and applicable contractor personnel—nearly
22,000 individuals, or 20 times the number vetted for TW 1.5. In addition, the PSB must
also significantly increase the level of continuous vetting services it provides from TW 1.5 to
TW 2.0 in 18 months. This rapid increase in workload, both in population served and
services provided, will require sufficient implementation capacity, including more PSB staff
who are appropriately trained to conduct continuous vetting tasks in a timely manner. If the
PSB plans now for its additional resource needs, it will prevent delays in full TW 2.0
implementation, reduce national security risks, and ensure a fair and effective personnel
security program.

If the EPA does not adequately plan to increase the PSB's
capacity to respond to a 20-fold increase in employees
receiving continuous vetting services, delays in processing
and managing full TW 2.0 implementation may increase the
risk to national security from insider threats.

Recommendation and Planned Agency Corrective Action

We recommend that the assistant administrator for Mission Support develop a plan for
how the PSB will achieve the capacity necessary to meet the requirements of full TW 2.0
implementation. The Agency agreed with our recommendation and provided an
acceptable planned corrective action and estimated milestone date. We consider the
recommendation resolved with the corrective action pending.

Address inquiries to our public
affairs office at (202) 566-2391 or
OIG.PublicAffairs@epa.gov.

List of OIG reports.

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