Numerous federal employees, plus some members of Congress, have been expressing concern about the implications for continued eligibility to hold security clearances—necessary for many federal jobs—among those who fell behind on financial obligations due to being unpaid for more than a month.

Although neither OPM nor OMB has put out guidance on that issue, one agency, HUD, had this reassuring statement in information it is providing to its employees:


“A furlough is a circumstance beyond an employee’s control. The Federal Adjudicative Guidelines specify that the adjudicative process is the careful weighing of a number of variables known as the “whole person concept.” Mitigating factors include whether the conditions that resulted in the concern were largely beyond the employee’s control and whether the individual acted responsibly under the circumstances. As a proactive measure, employees are encouraged to contact the Employee Assistance Program for financial guidance.”

Some federal workers with expertise in the area meanwhile are calling attention to a memo that, while issued in 2014 by President Obama, has not been overridden by any later policy. That memo says that agencies “shall not remove, suspend, or demote a current federal employee if the basis of the action is that the employee has experienced, or is experiencing, financial difficulty through no fault of the employee, and the employee has undertaken a good-faith effort to meet his or her financial obligations.”

Later OPM guidance on the memo says that agencies “should always consider whether the non-payment of debt was deliberate or through no fault of the individual . . . An individual’s deliberate financial irresponsibility and unwillingness to satisfy debts or failure to admit financial delinquencies may raise an honesty concern. However, no such suitability or fitness concern exists when the financial issues have been admitted and were incurred through no fault of the individual,” it says.