How the Security Clearance Process Works

To obtain a Personnel Clearance (PCL) for Department of Defense (DoD) clearances, a cleared contractor or DoD Government agency must first identify an employee or employment candidate who requires access to classified information. Once identified, the contractor’s Facility Security Officer (FSO) or the Government agency’s Security Manager (SM) submits an investigation request through the Defense Information Systems for Security (DISS) and ensures that the individual completes an electronic security clearance application, known as eApp. The FSO then reviews, approves, and forwards the completed eApp to the Adjudication and Vetting Services (AVS) within the Defense Counterintelligence and Security Agency (DCSA) for their approval, issuance of an interim clearance if applicable, and release for investigation. For most federal employees and all military personnel, the Government agency SM reviews, approves, makes an interim clearance decision, and releases the completed eApp to DCSA. DCSA conducts an investigation and sends the results to the AVS, which either grants a clearance or issues a Letter of Intent to deny clearance with a Statement of Reasons. Clearances for other federal agencies follow a similar process, but may involve a different Investigation Service Provider (ISP).

A National Agency Check (NAC), police record checks, and credit check are components of all clearance investigations. When possible these are done centrally by an Investigation Service Provider (ISP), like OPM. Some police record checks must be done locally by field investigators. “Letter Inquiries” to employers, employment supervisors, etc. are also done centrally by an ISP. For investigations requiring other record checks, reference interviews, and a Subject Interview, tasking is sent from the ISP simultaneously to different field offices and assigned to individual investigators (either federal agents or contract investigators) in all locations involved. If the investigation develops information that requires additional action in another location, tasking is sent from the investigator that developed the information to another field office. Investigative reports are electronically submitted as the work is completed. When all reports have been received at the ISP, the case is reviewed for completeness, and then forwarded to the appropriate Central Adjudication Facility (CAF).

The end-to-end processing time for a security clearance is primarily dependent on the type of clearance required, the federal agency involved, and the absence or presence of significant unfavorable information.

Under the 2004 Intelligence Reform and Terrorism Prevention Act (IRTPA) federal agencies are required to complete the fastest 90% of all initial clearances (Secret and Top Secret) in an average of 60 days (not counting the 10 or 12 days required for case submission). This average for the fastest 90% can include completion times ranging from 30 to 180 days. The remaining 10% can take from 6 months to over a year.

For a few years, starting in about 2010, federal agencies were generally able to meet the IRTPA timeliness requirements. However, a number of events beginning in fall 2013 caused delays in both investigations and adjudications. The ability of Government agencies to meet the IRTPA requirements is largely dependent on funding. Although recent technological advances have reduced some of the manpower intensive aspects of investigations and streamlined other processes; new investigative requirements have added to the cost and time required for investigations. Many new changes are being implemented and will continue being implemented. It is not possible to know what impact they will have on timeliness for the foreseeable future.

No. A new application will need to be submitted and a completely new investigation will need to be conducted and adjudicated. If unfavorable information in a case was fully covered, and favorably adjudicated during the prior clearance processing, it could speed up the adjudication phase of a new clearance request.

No.

Some security clearance determinations are made relatively quickly. Others may take a year or more. For these cases part of the answer involves the applicant and requires a better understanding of the process. There are three phases to clearance processing: 1) application, 2) investigation, and 3) adjudication. In the past most clearance delays occurred during the investigation phase. Due primarily to a significant increase in the number of investigators, the average time for investigations has been significantly reduced. Today most of the delays in getting a clearance occur in the application phase and the adjudication phase. The problems that cause these delays are:

1. The applicant is not available for a Subject Interview
2. Missing or inaccurate data on security clearance application forms
3. Problems involving fingerprint submission
4. Serious security/suitability issues
5. “Queuing time”

Problem #1 occurs during the investigation phase and is usually due to the applicant being out of the country. If the applicant is in a war zone, the Subject Interview is usually conducted when the applicant returns to the United States. There can also be substantial delays when an applicant is in a location such as Germany, Japan, Great Britain, or South Korea.

Problems #2 and #3 occur at the application phase and can result in an application being rejected by the CAF or ISP and returned to the requestor. About 5% of all clearance applications are rejected. This can result in delays of 30 to 60 days. Reviews of applications at the CAF and at the ISP before an investigation is opened can only discover obvious errors and omissions. These reviews do not discover wrong addresses, telephone numbers and dates, nor do they discover omitted foreign travel, relatives, residences, employment or education. These errors and omissions are only discovered during the investigation phase where the case can also be delayed.

Problems #4 and #5 occur primarily at the adjudication phase and can result in much longer delays. Serious issues may require additional information or investigation. When a CAF requests additional information or investigations, it can delay a case for months. A certain amount of queuing time is necessary for efficient operations, but when there is a backlog of cases with major issues, queuing time becomes excessive.

1. Download a fillable PDF copy of the application form (Standard Form 86— SF86) from the OPM website. Complete the PDF copy of the SF86 before attempting to complete the web-based (e-QIP) version online. You will save yourself a lot of time and frustration.
2. Provide complete and accurate information. Too often applicants fail to list short-term employment, residence, education, and other seemingly unimportant information. When an investigation turns up missing or discrepant information, it adds extra time to the investigation. Among other things, failure to list the organization that is sponsoring your clearance as your current employer may cause your application to be rejected.
3. Postal Zip Codes are critical. A wrong Zip Code can result in part of your investigation being sent to the wrong investigative office, and the case could languish for days before the error is noticed.
4. Get a free copy of your credit report from each of the three national credit reporting agencies at www.annualcreditreport.com and review them before completing an SF86. Something you were unaware of may appear on one of the reports and cause delays.
5. When entering the “Name of Person Who Knew You” in the Residence Section of the SF86, try to list neighbors. Avoid listing relatives in any section of the SF86, except Section 17—Marital Status and Section 18—Relatives.
6. Don’t indicate dual citizenship just because you were born in a foreign country, unless you are certain you have dual citizenship. Go to http://www.multiplecitizenship.com/documents/IS-01.pdf and check the citizenship laws of the foreign country where you were born. This document is old and may be inaccurate, but it’s a good initial reference document. If you have dual citizenship, you should indicate in the SF86 your willingness to renounce foreign citizenship.
7. If you have been hospitalized for specific medical conditions or been diagnosed by a physician or healthcare professional with a mental health condition in the past 7 years, contact the facility or physician and determine if they will accept standard government forms for release of information concerning your condition or treatment. If not, get a blank copy of a release acceptable to your clinician and take it with you when you are interviewed by an investigator.
8. If you left a job under less than favorable circumstances, explain the situation in the “Add Optional Comments” field of Section 13 of your e-QIP, and give the name and/or position of the person who terminated you or asked you to quit.
9. Couch any unfavorable security and suitability information in terms directly applicable to the mitigating conditions listed in the Adjudicative Guidelines. On December 10, 2016 the Director of National Intelligence signed Security Executive Agent Directive (SEAD) 4, "National Security Adjudicative Guidelines." There are 13 guidelines covering such things as alcohol consumption, drug involvement, financial considerations, criminal conduct, etc. Each provides examples of potential disqualifying conditions and mitigating conditions. There are also “General Criteria” listed at paragraph 2 of the Adjudicative Guidelines that are applicable to all of the 13 guidelines.

There are 4 sections of the clearance application (“Where You Have Lived,” “Where You Went To School,” “Your Employment Activities,” and “People Who Know You Well”) that require names and contact information for people who can be interviewed as references. Unless there is no other choice, do not list any relatives in these sections. For your residences you should list current and former neighbors. For employment you should list current and former supervisors. If you believe the investigator will have trouble locating a former supervisor, use the “Add Optional Comments” field and add contact information for a former coworker or second tier supervisor. For schools you should list former classmates or faculty members who will remember you. For “People Who Know You Well” try to list at least one person who has known you for the past seven years and who knows who your other friends are. Try not to list the same person more than once on your clearance application.

If you are being investigated for a Top Secret clearance or for a Secret clearance that requires access to a designated Secret Special Access Program (SAP), an Enhanced Subject Interview (ESI) is a regular part of the investigation. ESIs can also be required in an investigation for a Confidential or Secret clearance, if a suitability/security issue is listed on your clearance application or surfaces during the investigation. A Special Interview (SPIN) can be required in any investigation, if a previously undisclosed suitability/security issue surfaces after an ESI was conducted.

During a ESI, the investigator will cover every item on your clearance application and have you confirm the accuracy and completeness of the information. You will be asked about a few matters that are not on your application, such as the handling of protected information, susceptibility to blackmail, and sexual misconduct. You will be asked to provide details regarding any potential security/suitability issues. During a SPIN, the investigator will only cover the security/suitability issue(s) that triggered the SPIN. The purpose of the SPIN is to afford the applicant the opportunity to refute or to confirm and provide details regarding the issue(s).

You must answer all questions on the clearance application form truthfully and completely, but you do not have to volunteer unfavorable information that is not related to any of the questions on the form. Many clearance denials for financial problems, drugs, alcohol, and criminal conduct also involve intentional omission of relevant information and/or providing false information during the clearance process. Often the act of providing false information is more serious than the issues people try to hide. Passage of time is a major mitigating factor for all issues involving misconduct. Willfully providing false information on a clearance application or during a Subject Interview is a serious criminal offense and is very difficult to mitigate because of the recency of the offense.

1. Fingerprints not received within the required timeframe of 14 days
2. Missing information on employment
3. Missing information on references (education, employment, and/or character references)
4. Illegible Certification/Release forms
5. Certification/Release forms not meeting date requirements
6. Missing information on relatives
7. Missing Selective Service registration information
8. Incorrect date or place of birth (i.e. information on fingerprint form and SF86 don’t match)
9. Missing financial information
10. Missing information on cohabitant
11. Missing information on spouse
12. Incorrect Certification/Release form number
13. Incorrect social security number

To find out the status of your security clearance application, you should have your Facility Security Officer (FSO) inquire about it. For Department of Defense (DoD) clearances, the FSO can check the status using the Defense Information System for Security (DISS). If your clearance is with the Intelligence Community, the Scattered Castles system is used. Note that these systems do not communicate with each other, so if you have clearances with multiple agencies, your security officer may need to check multiple systems.

If you are not currently employed, you can make a Privacy Act request through the Defense Counterintelligence and Security Agency (DCSA) to obtain information about your security clearance status. This request can be made via mail, fax, or email.

Normally you will be contacted by your security office, receive a security briefing, and be required to sign a “Classified Information Non-disclosure Agreement,” immediately prior to being granted access to classified information.

• current unlawful use of or addiction to a controlled substance

It is extremely difficult to mitigate the following security issues:

• determined to be mentally incompetent by a mental health professional approved by DoD
• criminal conviction resulting in incarceration for a period of one year or more
• discharge or dismissal from the Armed Forces under dishonorable conditions

Otherwise, the most common reasons for clearance denial are serious financial problems, intentional false statements in connection with a clearance investigation, recent illegal drug involvement, repeated alcohol abuse, and a pattern of criminal conduct or rule violation. For many people these issues can be mitigated, if presented properly during a security interview or in response to a Letter of Intent to deny clearance.

The National Security Adjudicative Guidelines list various conditions under 13 separate guidelines that could result in clearance denial.

When a case contains significant unmitigated derogatory information, the adjudicator issues a “Letter of Intent” (LOI) to deny a clearance. The LOI is a preliminary, tentative decision and will contain a “Statement of Reasons” (SOR) detailing the issues that are the basis of the decision. Some agencies issue a Letter of Denial with an SOR, but it is essentially the same as an LOI. The LOI contains instructions on how to request a copy of the investigative file on which the decision to issue the LOI was based.

Federal contractor personnel can submit a written rebuttal to the SOR and request a hearing. If the applicant doesn’t submit a rebuttal to the SOR, DoD CAF will deny the clearance. If the applicant rebuts the SOR without hearing, DOHA sends the applicant a File of Relevant Material (FORM) that will be presented to an Administrative Judge (AJ) for a clearance decision based on the written record. The applicant can submit a written response to the FORM, which will also be presented to the AJ. If the applicant requests a hearing, the applicant (with or without an attorney or personal representative) may present witnesses and other evidence at the hearing. The applicant may also cross-examine witnesses and challenge evidence presented by the DOHA Department Counsel (an attorney representing DoD). The AJ makes a written decision and a copy is sent to the applicant. DOHA then grants or denies the clearance in accordance with the AJ’s decision. If the clearance is denied, the applicant is notified in writing and advised of their right to appeal the decision. It is possible that the DOHA Chief Department Counsel could grant the clearance after reviewing the applicant’s response to the SOR, thus obviating the need to present the case to an AJ.

DoD civilian employees and military personnel can submit a written rebuttal to the SOR, but they are not entitled to a hearing. If the applicant doesn’t rebut the SOR, DoDCAF will deny the clearance. If they submit a rebuttal to the SOR, the adjudicator will decide to grant or deny the clearance in light of information submitted in the rebuttal. If a decision is made to deny a clearance, the applicant is notified in writing of their right to appeal the decision, including a right to a “Personal Appearance” before a DOHA AJ.

Any applicant may appeal a clearance denial or revocation to the federal agency’s three-member Personnel Security Appeals Board (PSAB). PSAB decisions are made by a majority vote.

Contractor applicants are limited to submitting a written appeal, but the DOHA PSAB will not consider any new evidence. The appeal must be based on procedural error(s) by the AJ. In industrial cases the DoD Department Counsel can appeal the favorable decision of an AJ. The PSAB issues a written decision addressing the material issues raised on appeal and a copy is sent to both parties. The PSAB can affirm, reverse, or remand a case to the original AJ with instructions for further review. If the original decision is reversed or affirmed, the decision of the PSAB is final.

DoD civilian employees and military personnel have the choice of submitting a written appeal with supporting documents directly to their PSAB or requesting a “Personal Appearance” before a DOHA AJ. In either case new evidence can be submitted. Those who choose to appear before an AJ are permitted to explain their case (with or without an attorney or personal representative), submit supporting documents, and present witnesses. Although a Personal Appearance is very similar to a hearing; there is usually no opposing counsel. The AJ evaluates all the information and makes a written clearance recommendation to the applicant’s PSAB. The PSAB is not required to follow the recommendation of the AJ. The PSAB notifies the applicant of their final decision and includes reasons for their decision.

Applicants who are denied a clearance with or without an appeal are barred from applying for a security clearance for a period of one year.

The EPSQ was the only electronic security clearance application used within DoD until July 2005, when it was gradually replaced by e-QIP.

E-QIP is an Office of Personnel Management (OPM) web-based computer program in which an applicant enters the same information as required on the “Questionnaire for National Security Positions” (Standard Form 86—SF86). E-QIP became available in July 2005 and slowly replaced the EPSQ. E-QIP now accounts for over 95% of all clearance applications.

JPAS was the official personnel security clearance database management system for DoD, including National Industrial Security Program (NISP) cleared contractors. This system was used for all types of personnel clearance actions, including initiating requests for clearance investigations. JPAS was managed by the Defense Manpower Data Center (DMDC).

The Defense Information Systems for Security (DISS) is a system developed by the Department of Defense to replace the Joint Personnel Adjudication System (JPAS). It serves as the security system of record for all Department of Defense personnel, including military, government civilians, and contractors. DISS is designed to improve the security clearance process by enhancing reciprocity, usability, and timeliness of back-end processing. It facilitates continuous vetting and better cross-communication among government agencies, making it easier for Intelligence Community agencies, Department of Homeland Security components, and law enforcement to access relevant information. DISS merges the Case Adjudication Tracking System (CATS) and Joint Verification System (JVS) and supports insider threat mitigation, continuous vetting, and eligibility determinations.

First you must determine who conducted your investigation. The Defense Security Service (DSS) and the Office of Personnel Management (OPM) have conducted more than 90% of all clearance investigations over the past 35 years. Due to the transfer of the DoD personnel security investigations function from DSS to OPM on February 20, 2005, any requests for investigations completed after February 20, 2005 should be sent to the OPM. DSS no longer maintains personnel security investigations completed by DSS prior to the February 20, 2005 transfer. Those records are available from the Defense Manpower Data Center (DMDC).

For OPM investigations submit OPM form INV 100 in accordance with instructions on the form.

For DSS investigations completed before February 2005 submit a written request to DMDC at:

Defense Manpower Data Center
ATTN: Privacy Act Branch
P.O. Box 168
Boyers, PA 16020-0168

Include the following information in your request:

• Full current name
• Any other names you may have used in the past
• Date of Birth
• Social Security Number
• A brief description of the records you are seeking
• Any other information that you feel may help in searching for records pertaining to you.
• The address where you would like the records sent.

In addition, you must provide a notarized statement or an unsworn declaration made in accordance with 28 U.S.C. 1746, in the following format:

If executed outside the United States: ‘I declare (or certify, verify, or state) under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on (date). (Signature).’

If executed within the United States, its territories, possessions, or commonwealths: ‘I declare (or certify, verify, or state) under penalty of perjury that the foregoing is true and correct. Executed on (date). (Signature).’

For all other federal agencies contact the agency’s Freedom of Information and Privacy Act office (or visit their website) for instructions.