DCSA Updates Periodic Reinvestigation Guidance for Contractors

A recent announcement published by the Defense Counterintelligence and Security Agency (DCSA) reflects changes that will affect all DoD contractors regarding having to submit their SF-86 (soon to be PVQ) updates for periodic reinvestigations. This updated guidance aligns with policy guidance military and government civilian personnel are already following. The new policy negates the need for periodic reinvestigations and instead requires that all contractors who fall under the National Industrial Security Program (NISP) must now submit an updated Personnel Vetting Questionnaire (PVQ or SF-86) every five years, regardless of their clearance level. The timing for this five-year update is now based on the “PVQ Date” recorded in DISS, which is equivalent to the last SF-86 date.

Previously, DCSA used the Continuous Enrollment (CE) date for when a new PVQ update was required, but it left a gap in timelines from when the last PVQ update was submitted since it may have occurred a year or two later. Previous policy was also confusing to personnel security managers when trying to assess whether they could accept reciprocity for new employees in-processing from other agencies.

There remains a glitch in the process, however, for those individuals moving from an Intelligence Community (IC) agency to the DoD. The IC agencies use Scattered Castles to record their investigation and clearance information, which does not include the date of the last PVQ update or CE date. This means that the information transferred between Scattered Castles and DISS, the system used by the DoD, is incomplete. The guidance provided by DCSA requires that these individuals submit a new PVQ update regardless of when their last investigation was completed so that they can be enrolled in DoD’s CE program. You can read the full policy guidance here.