
OPM has announced plans to begin replacing periodic reinvestigations with “continuous vetting” for federal employees holding security clearances who are in positions designated as “non-sensitive public trust,” with a goal of having the new policy apply to all of them by the end of the current fiscal year.
Continuous vetting involves conducting at any time the kinds of checks done in a periodic reinvestigation to determine whether an individual continues to meet the requirements for a clearance. It already is in common use in intelligence community agencies and for employees with high-level clearances generally.
According to a fact sheet accompanying the memo, it commonly involves: automated checks of records in government or commercial databases; information held by the employing agency such as insider threat program data, security violations or other information of concern; investigative work at certain intervals or after certain events, potentially including interviews of the employee and work or personal references.
“If concerning information is found, that information is assessed to determine if it is accurate, relevant, timely, and adjudicated,” it says. Adjudication potentially could result in loss of a clearance, which in many cases effectively would result in loss of the job.
The action, announced in a memo on chcoc.gov, follows a pilot program conducted over the summer. “Enrollment will proceed iteratively, with a goal of enrolling 100% of this population into an initial capability in FY 2024,” the memo says, adding that further instructions are to come.
“Until agencies begin enrollment of their non-sensitive public trust populations into continuous vetting, they must continue to initiate reinvestigations for individuals occupying these positions in accordance with existing policy and established protocol. Doing so will ensure that agencies are in compliance with the regulatory requirement and avoid potential delays in mobility for applicants or employees caused by out-of-scope investigations,” it says.
The policy follows a series of changes to rules and executive orders regarding reinvestigations requirements of employees holding clearances that vary according to the level but generally have been required at least every five years. That includes a 2017 order generally requiring continuous vetting for competitive service federal employees.
OPM also noted that earlier this year it proposed rules to extend continuous vetting to excepted service, non-appropriated fund and “contractor staff-like positions.” The comment period is now closed and guidance will be issued when the rules are finalized, it said.
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