Background Investigations

OPM Issues Guidance for Personnel Vetting During COVID-19 Crisis

It isn’t just federal employees or contractors in the Pacific Northwest who are being instructed to telecommute. The Office of Personnel Management (OPM) has also urged agencies to ensure that federal employees are prepared to telework, and earlier this month it issued new preliminary guidance on how this should be carried out. Week to week, the news has changed that guidance.

OPM, in collaboration with the Defense Counterintelligence and Security Agency (DCSA), issued guidance last week for all Federal agencies regarding personnel vetting and fingerprinting for new hires. Many agencies have shut down badge and fingerprint enrollment stations, hindering new hire background investigation applicants from getting fingerprints submitted. Here is a brief summary of the memorandum from OPM:

  • Agencies that have the ability to submit fingerprints electronically, process and submit e-QIPs, and issue badges will continue to do so
  • Agencies that do not have the ability to submit fingerprints electronically can continue to process new hires using agency guidance and use risk based procedures methods such as local records checks, remote identity document verification, and other methods. However, in-person I-9 documents must be completed when agencies are able to
  • DCSA will process background investigation submissions without fingerprint submissions, but agencies must submit them once they are able to. Investigations closed before fingerprints are submitted and FBI criminal history checks are completed cannot be adjudicated until done.
  • Agencies will not be held to adjudicative reporting timelines until processes have returned to normal

Per regulatory guidance Common Access Cards or Personal Identity Verification badges cannot be issued without a favorable criminal history check and in-person enrollment. Agencies do have the latitude to issue alternative credentials until such a time as all requirements have been met.