OPM Issues New Notices Concerning SF86, Clearance Costs and Reciprocity
The Office of Personnel Management (OPM) has posted 4 new Federal Investigations Notices (FIN) on their website all dated August 29, 2011.
FIN 11-04—“Continuous Efforts to Align with Reciprocity Goals and Timeliness Standards.” This FIN fully implements interim adjustments made to National Investigative Standards by a August 2010 joint memorandum issued by OPM and the Office of the Director of National Intelligence (ODNI). This represents a significant retreat from the 3-tier concept approved in December 2008 and fails implement one of the major purposes of Executive Order 13467. E.O. 13467 called for a system where “Each successively higher level of investigation and adjudication shall build upon, but not duplicate, the ones below it.” As long as suitability/fitness investigations are based on an SF85 or SF85P, there is no possibility that these investigations, no matter how current or comprehensive, can be used to grant a national security clearance, which must be based on the submission of an SF86.
FIN 11-05—“Investigations Reimbursable Billing Rates for FY 2012.” With one exception prices for standard OPM investigative products did not increase from FY 2011. OPM states that “For FY 2012, we intended to apply an across the board ESI cost to all national security NACLC and ANACI investigation prices. We are deferring this pricing change, however, to permit us to use FY 2012 data to assess the rate at which issues are triggered on investigations submitted on the revised SF86.” Since ESIs will only be conducted on these investigations if triggered by security/suitability issues, prices for all NACLC and ANACI should only increase a percentage of the current price of $550 for an ESI based on the percentage of investigations that require an ESI.
FIN 11-06—“Special Agreement Price Schedule.” A few Special Agreement Checks (SAC) were increased by $2 and the others remained unchanged from FY 2011 prices.
FIN 11-07—“Discontinuing the 2008 Standard Form (SF) 86; Implementing the Fully Electronic 2010 SF 86.” Both the paper and e-QIP versions of the 2008 SF86 will become obsolete on October 1, 2011 and no longer accepted by OPM. However, 2008 SF86s submitted prior to October 1, 2011 will be processed and 2008 SF86s returned to applicants due to missing information may be resubmitted without converting them to the new form. Additionally OPM will no longer accept paper copies of SF86s; however, a special process has been created to enable Third Party Data Entry (3PDE) where applicants are unable to directly enter into e-QIP themselves. A “Fillable/Printable” PDF version of the 2010 SF86 will be posted to the OPM forms webpage on October 1, 2011.