Background Investigations

OPM’s 5 Tiered Background Investigations System Draws Unfavorable Comments

Late last Fall the Office of Personnel Management (OPM) implemented the first 2 tiers of the new 5-tier background investigation process that was approved through collaboration between OPM and the Office of the Director of National Intelligence (ODNI). Although OPM did not send out an official notice to the field that they were implementing Tiers 3 and 3R (reinvestigation) effective in FY 2016, they have now been incorporated into the new billing standards (Federal Investigations Notice No. 16-01 issued on October 2, 2015). OPM still has not revealed when it will implement Tiers 4 and 5. Below are what the new tiers look like:

Tier 1 (uses the SF-85 form)

– Non-Sensitive Low Risk positions/Physical and/or Logical Access (HSPD-12)

Tier 2 (uses the SF-85P form)

– Non-Sensitive Moderate Risk (Public Trust) positions

Tier 3 (uses the SF-86 form)

– Non-Critical Sensitive positions requiring Confidential, Secret or “L” (Department of Energy or DOE) Access Eligibility

Tier 4 (uses the SF-85P form)

– Non-Sensitive High Risk (Public Trust) positions

Tier 5 (uses the SF-86 form)

– Critical Sensitive positions requiring Top Secret, Sensitive Compartmented Information (SCI), or “Q” (Department of Energy or DOE) Access Eligibility

Initial comments from the field (e-QIP initiators, investigators, reviewers) have not been very favorable. Specific comments from investigators indicate that there is a lot of confusion as to what types of checks are needed (in person or record) and what can be written off when they are unable to complete the check. The new certification process is also a hot topic of discussion, with investigators and reviewers having to score 100% on the test. It seems that OPM continues to conduct business as it has in the past,  pursuing its own agenda and disregarding advice and feedback from the field. OPM communications with relevant information are non-existent, unless or course, it is to notify agencies of cost increases in their investigative products.

Comment Archive

  1. Avatar

    In OPM BI interviews I had a long history of developing very good information, even some deep dark secrets, through skilled questioning and building rapport, along with some acting and bluffing. I always knew I was taking a chance because if anyone complained about me as a contractor I would be looking for a new job. But over the last few years I have approached the process robotically and have reduced my interviews to just asking all the required questions. Not because I feel good about doing this, but in the last few years the process– especially the ODNI requirements– has become tediously bureaucratic with more and more required questions which are mostly irrelevant at best, and often stupid. How many times do I need to ask a person about possible involvement with/in a terrorist organization? Really? You don’t hit people with nuclear option questions. You make them feel comfortable and then gently throw out a broad net. “So, have you had any contact with a group or maybe a person you think might be questionable. Not that you had anything to do with it, but maybe they approached you… I mean, believe it or not in this day and age it’s more common than you’d think…” The OPM approach is like a homicide detective asking, “Did you commit murder? Did you agree to commit murder? Did you conspire to commit murder?” A seasoned detective will approach a suspect like a buddy. “Look, we all do stupid things, If something went wrong and even if you didn’t intend anything it’s better to just tell us now so we can straighten things out and not make it worse.” But I guess the OPM investigation process is relying on the inherent power of questions, per se, because the OPM S/A who did my ESI rarely looked up at me while rattling off all the required questions and seeing to it the RESI-EMPL timeline was ROI ready. It’s a travesty that is only compounded by the fact that the majority of the process is outsourced to for-profit companies.

  2. Avatar

    You are exactly right, sir. The BI process as now constituted is a shambolic waste of time and the taxpayers money. Compounded by inane review staff who labor over every jot and tittle but miss the elephant in the room! And now, one contracting company is micromanaging investigators to the point they are told only an 8.5 x 11 size paper is authorized for note taking–or you will be written up for a security violation! I personally know one investigator who has. Unbelievable. Meantime, as the vultures squabble for their piece of the action, national security concerns are of little value.

  3. Avatar

    An update to this posting, OPM issued FIN 16-02 yesterday notifying all agencies that they were now implementing Tier 3/3R. This appears to be an afterthought on their part since they already started charging agencies for it on 10/1.

  4. Avatar

    OPM inconsistent about implementing policy? Shocking!