Security Clearance Denial

Question 21, Counseling and Security Clearance Applications

The issue of mental health stigma has always surrounded question 21 of Standard Form 86 (SF-86). It’s a fact that few applicants are denied a clearance based on listing mental health counseling on the security clearance form. But experts argue that including the question will prevent some from seeking help in the first place, knowing they’ll need to list any counseling on a future security clearance application or reinvestigation.

On September 4th, the Department of Defense emphasized its commitment to making the counseling received by victims of sexual assault more private. According to a DoD memo victims of sexual assault must still list any counseling received on their SF-86, but when it comes to using information about that counseling to make a clearance determination, the basis will be a yes or no question directed toward the individuals’ physician – ‘does the applicant have a condition that could impair their judgment or ability to safeguard classified information?’ If the answer is no, no further questions will be asked.

The memo seems to be a face-saving response to critics of requiring victims of sexual assault to answer the question. When similar criticism of mental health counseling stigma for victims of Post-Traumatic-Stress were reported, the Department of Defense in 2008 clarified that service members did not have to report counseling related to combat stress. In contrast, DoD is not excluding sexual assault counseling from reporting requirements, but is emphasizing its commitment to privacy for sexual assault victims.

When it comes to investigating a psychological condition, current practice as it already stands is to simply direct a yes or no question to the mental health practitioner providing the counseling. If the answer of impaired judgment or ability to safeguard information is no, information about the applicant’s condition aren’t released – regardless of the reason for the counseling.

In a recent interview, “Can Counseling Complicate Your Security Clearance?” Evan Lesser, ClearanceJobs founder and managing director, noted that security clearance investigations today are looking at the big picture surrounding an individual’s character and history, and also recognize the increased prevalence of mental health counseling. While counseling may have been an issue in the past, that isn’t the case today.

“They take into account the totality of someone and their actions, their circumstances, how they got there,” Lesser said.

Director of National Intelligence James Clapper has said he’s looking into proposals to amend the SF-86 to remove requirements to report sexual assault related counseling.

When it comes to security clearance adjudication, policy is clear that mental health counseling  in and of itself is not a justification for a clearance denial, regardless of the reason for the counseling. Practically speaking, however, it certainly could prevent an interim clearance.

Comment Archive

  1. Avatar

    Common sense says we should not ask victims of sexual assault anything. The victims are already being handled by professionals through their unit leadership, who owns the classified material. If the Commander feels there is a problem–then put it on them to decide with the help of the counselors, not in our hands. There are no details of sexual assault important enough for us to make a victim re-live the events.

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    Having been a rape victim undergoing this process, I was appalled at the behavior of the investigator. After being told what my counseling was for, he inquired into the details of the assault, basically asking me to retell him the entire event. He then went to my commander and asked him about it. My CO knew I was in counseling but not what for. It was completely retraumatizing.

    Those who focus on the award or denial of clearance aren’t getting the point when rape victims raise questions about this issue. I have PTSD from rape. My male colleague has PTSD from combat. I have to relive the experience with a stranger, whereas my male colleague can get the amount of counseling he needs without having to have it discussed on his security clearance. Further, the approval of my final clearance was delayed while it was in adjudication. All because I had the misfortune of being raped.

    I know many servicemembers who categorically refuse to seek counseling because of question 21. The bottom line is it deters help-seeking behavior. Those who would say that it is better to seek help than to keep going until one has an incident clearly have not considered a person’s ability to endure pain and suffering because his or her’s job depends on it.

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    IMO, counseling/treatment for mental/emotional issues is something that can be left to the ESI. A lot of times people don’t list it anyway, “Oh, I didn’t list it because I thought seeing a psychiatrist didn’t count as psychological or emotional…”

    What about asking a Subject if he or she has ever been involved in armed protests of the U.S. Government or military? Or even with the last seven years, which would have required required a “yes” in 1976 for the following:

    As a freshman at Columbia University in 1970, future Attorney General Eric Holder participated in a five-day occupation of an abandoned Naval Reserve Officer Training Corps (ROTC) headquarters with a group of black students later described by the university’s Black Students’ Organization as “armed,” The Daily Caller has learned.

  4. Avatar


    I’m with you 100%. This is something we don’t need to explore in an interview. I agree PTSD is just that no matter the reason. I personally am sorry you had to re-live the experience. I have had a few cases like yours, but why the investigator went to your CO has me puzzled.

    This is better left to Commanders, F/Sgt’s and mental health professionals.

    On another note, I am a retired military criminal investigator and at one time pushed 300+ troops. The troops need to know that seeking help should be their first priority. The days of the old way of thinking, needs to be shunned. I personnaly took some of the kids to the clinic myself to help them. They were treated and back to full duty.

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    When you say that your Investigator asked your CO about ‘it.’ Do you mean the rape or the counseling?

    Sounds like there may have been some issue resolution attempted and in which case, the Investigator may not have been all that out of line. It would depend on if the Investigator gave out info instead of collecting it.

    That being said, I agree with BW 100%. This policy is one that should be changed, swiflty.

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    I am a retired DoD security adjudicator and a retired military member. I am in complete agreement that being treated for any mental/emotional problem should NOT be a reason to deny/revoke a security clearance. And for the most part, that is the case. Sheila, I am very sorry for your situation and in my opinion, your investigator went way beyond investigative requirements and he needs re-trained. When Question 21 was changed years ago to exclude treatment “related to adjustments from service in a military combat environment”, most adjudicators were against the change. I believe that there are thousands of people who have PTSD from combat and are not being treated or are not in compliance with their treatment. Such people should not be granted a clearance, but we don’t know because they are not required to admit to their situation. The common sense application of this adjudicative guideline is based on the opinion of a qualified mental health professional (in the old days it was competent medical authority) the person being considered does not have a condition that may impair judgment, stability, reliability or their ability to protect national security in formation. Being treated is not disqualifying.

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    re: Federal Investigator
    When I said that the investigator asked my CO about “it” I am saying that he went to my CO and said, “were you aware your subordinate was in counseling for rape?” My CO responded “I was aware she was in counseling. I never inquired as to the reasons because I’ve never had reason to. She’s a dependable and reliable subordinate.” (all hearsay, of course, b/c I wasn’t present. But this is what my boss told me.) I deeply resented having the fact that I was raped shared with my boss, especially as it caused him to treat me differently (though i was out of concern for me)and it basically wierded out my chain of command. Plus, being asked details about the assault itself was humiliating. After thinking I had been able to move on from the assault being forced to relive it was probably one of the worst days of my Army career.

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    Sheila –

    I’d report that investigator to OPM immediately. OPM will conduct an inquiry. Background investigators are barred from asking the kind of question your CO recounted; investigators are strictly disallowed from giving out ANY information about you to anyone other than OPM in the form of a Report of Investigation.

    This is the OPM-OIG web site. Here’s an excerpt:

    We also investigate misconduct by OPM employees or contractors; fraud in OPM contracts; fraud in OPM’s revolving fund activities; and fraud, waste, or abuse in the variety of other programs administered by OPM. Examples of OPM programs include, but are not limited to, the personnel security and suitability program managed by OPM’s Federal Investigative Services (FIS), the Combined Federal Campaign, the Federal Executive Institute and Management Development Centers, USAJOBS, and Nationwide Testing. Anyone who wishes to report allegations of fraud, waste, or abuse committed by OPM employees, OPM contractors, or affecting any OPM program, may contact our Retirement and Special Investigations Hotline.


    Insurance Fraud, Retirement and Special Investigations
    (877) 499-7295

    Or Write To:

    OPM Office of the Inspector General
    1900 E Street NW Room #6400
    Washington, DC 20415-0001

  9. Avatar


    You’re investigator overstepped their bounds by revealing info to your CO. That is really sh*tty and I’m sorry.

    As far as having to discuss the details in your ESI, hopefully you can help effect the change in policy that is needed.

  10. Avatar

    Personally I think Question 21 should be completely eliminated. If it can’t be eliminated, then all the exceptions to Question 21 should be eliminated. About 9% of the general population receives mental health treatment each year. But less than 10 DOHA (defense contractor) cases out of 150,000 cases a year (less than 1/100th of one percent) result in a clearance denial or revocation due to “Psychological Conditions.” In some of these cases there was no mental health counseling. When a person’s judgment is impair due to a mental health condition, there’ll be other indicators and the question of counseling can be covered during a Subject Interview.

    If they can’t eliminate Question 21 and they can’t eliminate the exceptions, then they need to rethink the reason for the exceptions and rewrite them in a way that makes sense. If you have an exception for counseling for the victims of trauma, then all forms of trauma should be included, not just trauma from combat. If there are exceptions for family and marital counseling, then there should be exceptions for other forms of relationship counseling. What about counseling due to adolescent adjustment problems? What about social anxiety, stress, or mild claustrophobia treated by a family physician? Once you allow exceptions, it’s kind of hard to stop. Everyone to some extent has privacy concerns about medical issues, particularly mental health. Background investigations by their very nature are intrusive; they have to be. But they don’t have to be massively intrusive. There’s no reason an investigator has to ask the Subject of the investigation “why” they received counseling or any other details except for dates and the counselor’s contact information. If efforts to contact the counselor or get them to complete the “three-question” medical release form are unsuccessful, the government can have the applicant see a qualified mental health practitioner for an interview and evaluation.

    Too often people misunderstand or choose to misinterpret the exceptions to their advantage. Does the word “grief” mean the same thing as bereavement or is it okay to withhold information about counseling due to other causes of grief? Is it okay to withhold information about counseling that began due to communication problems between a married couple, but resulted in a diagnosis of bipolar disorder? Should you list current grief counseling even though the death of a loved one occurred three years ago and you’re still taking an anti-depressant?

  11. Avatar


    Thank you for all the information you have provided on your site. This has helped me a great deal to go through the majority of my clearance process. I was hired in June by a Fortune 500 company for their team of government contractors. So far, I have completed my SF-86 form and have sent relevant documents such as my passport, my parents’ passports, and my drivers’ license. I have met with my private investigator and he has interviewed my neighbors and references. Aside from one speeding ticket, I have not gotten into trouble, such as DUI or drugs. He has sent his feedback to Washington and I have been notified by my new company that I will now be scheduled for a polygraph. My question is how long will the scheduling take and if there is anything I can do to help speed up the process?

  12. Avatar

    I agree with Mr. Henderson, above.

    Q21 on the SF-86, ‘does the applicant have a condition that could impair their judgment or ability to safeguard classified information?’ is a red herring, an artifact of an era when misperception (and a desperate desire to rely on a final arbiter) imposed a paternalistic, dictatorial position onto the mental health profession. First, my qualifications for my stance, then the stance.

    I’m a civilian mental health professional with 25 yrs’ clinical experience (10+ in DoD), and 1 yr on the front lines in the OIF combat environment. While deployed, I regularly informed those serving that, if they had consulted with me, when the time came to resubmit the SF-86 they should check ‘no’ on Q21.

    Q 21 makes an assumption, and overlooks a motivation. Lost in the question is acknowledgement that those who seek counseling (used generically for any flavor of consultation with a social worker, psychologist, psychiatrist) show good judgment by seeking counseling in the first place (yes, I am, for the purposes of this piece, omitting the small population ordered into treatment). The assumption underlying Q21 is that the customer revealed material that implied poor judgment; yes, the good therapist will can dig for the information, but not always uncover it.

    As to the exception (that is, one does not have to answer ‘yes’) for treatment “related to adjustments from service in a military combat environment”, it’s a start but does not go far enough. It does not go far enough because it precludes those, such as Sheila, who have PTSD from other causes – and there are just as many in the military as in the civilian realm with PTSD acquired by means other than a combat environment.

    The intent behind Q21 seems to be to exclude those with poor judgment. If it does, how is it clearances were granted to the likes of Sgt Hasan Karim Akbar (Mar ’03 threw grenade into tent killing 2 US soldiers), PFC Manning (released State Dept cables), and MAJ Nadal Hasan (Ft Hood)? One could make the argument Q21 has denied clearances to others who may have revealed similarly poor judgment if they had “gotten through”; but the numbers and reasons of those denied is in the hands of investigators. Still, if 100% exclusion is the goal, Q21 needs serious refinement. It should be refined out of existence.

  13. Avatar

    John Smith

    Unfortunately there is no way to speed up the process. Most agencies set their own schedules and alot are behind due to need.

  14. Avatar


    Agree in part. Going to seek treatment is viewed as taking responsibility and following through on what the providers suggest as treatment.

    I fully agree that PTSD comes from many reasons……we investigators have no authority to determine what is qualifying/disqualifying. We simply collect the facts as they are presented and it’s no longer in our hands. We do not interject anything into the case….i.e..opinions or any observation facts. If we ask the question to the mental health folks and the answer is “No” we move along and simply check one block on the report.

    Not too long ago, we had to review mental health records as if we understood what was in them and had to report them. We are slowly moving in the right direction, but Government and common sense are not synonymous.

    Thanks what you did and continue to do for the troops.

  15. Avatar

    I inadvertently posted this in an inactive thread, so I’m reposting it here. Apologies for the “spamminess”.

    I have a few questions that I’m hoping the people here can answer. OPM is advertising BI positions in my area, and I am considering applying. I have some experience already; I used to be a CI agent in the Army Reserve and did a 6-month TDY augmenting the DSS (this was in the late ’90s). So I have some experience, but I don’t know how much has changed since then. Here’s the thing: I already work for the federal govt, and I’m reluctant to switch partly because I don’t understand why OPM uses so many contractors to do this job, and if that will have any potential impact on job security.

    I realize that this may sound like an odd concern, considering the generally accurate reputation the fed has for job security, but I seem to recall hearing vague rumors back when I was TDY to the DSS about some of their GS positions going away and being replaced by contractors. Is/has this been a problem? Given the obvious need for more investigators, why doesn’t OPM simply hire more instead of contracting it out? Considering how much contractors tend to charge the govt, I have a hard time believing that it’s actually cheaper.

    Thanks in advance for any insight you can offer. This blog rocks.

  16. Avatar

    JR–100% complete change since your days.

    Also, OPM Investigators are safe IMO. I don’t anticipate any increase in contractors as govt has to provide oversight. Believe me when I say that contract inv’s do not make nearly what OPM folks do, not even close. Contractors, especially subs are very cost efficient as folks like me have no benefits and receive no per diem or expenses.

    There will never be a day the govt can take this process back in it’s current form. This is the big Gorilla in the room and no way it can be run by one agency alone. There is some skilled OPM folks, but the bulk of the experience is in the contract world IMHO. Most of us old subs are retired CI, Crim Inv’s, Police Officers, Special Agents and Intelligence folks. I’m not knocking OPM Agents as many are great at their jobs (Calm down Fed :). I’m just knocking the govt’s ability to run a program this big, alone. Look at the TSA and you will understand.

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    JR–One last thing. DSS no longer does BI’s. They have downscaled based on their current mission–oversight of security programs.

  18. Avatar

    BW – Thanks for your response, and your insight.

    I’m not sure what you meant when you said, “There will never be a day the govt can take this process back in it’s current form. This is the big Gorilla in the room and no way it can be run by one agency alone”. Do you mean that combining all (most) of the federal agencies doing PSIs into one agency is a mistake/unsustainable?

    What is the general morale like for the GS investigators? I ask because, well, let’s put it this way: the agency I currently work for doesn’t fare so well in the federal employee satisation surveys… we’re in the 10% that makes the top 90% possible! You mentioned that most of the OPM folks (by which I think you mean GS 1810s, as opposed to contractors) are fairly young. Reading between the lines, it sounds like there’s a lot of turnover. How much of that is due to them getting hired on as 1811s somewhere, and how much is due to burnout/frustration with the job?

    It’s a change from the DSS, where many of the investigators weren’t all that young, and had been doing it for a while.

  19. Avatar


    Not that they are young per se, but when the contract positions started, we all had to have at least 5 years as a criminal investigator and a degree. OPM 1810’s do good work and I personally know many who are superior at the job. Now, most OPM Inv’s are brought in at GS 07, which does not draw alot of experience. But, in time they target GS 12. I was fortunate as a previous F/Time contractor and did well with pay, but the industry has stabilized and the starting wages for contractors is embarrasing for the amount of work these guys/girls produce. I don’t think OPM 1810’s have near the requirements we do for production, but hopefully Fed will chime in. I did full-time for years and had to interview at least 6-7 people per day, everyday and still write reports, while driving 300 miles–You can do the math. I will say, once you figure out a work/life balance, the freedom can’t be replaced, especially for us contractors who work from home and fully control our own schedules.

  20. Avatar

    JR–current form means that way too many folks needed and the process being so lengthy and tedious/time intensive. The big gorilla is the process and all the headaches from Congress. I’m pretty sure that is why the Defense Dept wormed their way out of this mess.

  21. Avatar

    BW is right on the money. Job security seems good but you always hear that DOD is taking back over or that all Investigators will be contractors so who knows. OPM seems to have made big strides in reciprocity, timeliness And technology. Its not perfect but the advances are major compared to other government agencies.

    As far as work load, it depends on the office. My prior office was pretty slow, so lots of TDY, which I loved but other did not as you have to go if there are not enough volunteers.

    My current office is crazy busy, Im hitting 5 to 6 sources per day and carrying well over 1000 MOC’s. You have to also remember that when you call in sick, the deadlines dont move, so you end up screwing yourself. On the other hand, the freedom the job brings you is second to none.

    The successful investigators look at the job as a service, you work nights and weekends to accommodate others schedules as needed. Investigators who try to work the job 9 to 5, quickly find nothing but frustration. You also have to learn to roll with the punches, you’re asking for information from sources, with no real authority, so your people skills have to be superior, there is no way around it.

    Our pay is good but you can easily compare that to other Fed positions.

  22. Avatar

    “Job security seems good but you always hear that DOD is taking back over… ”

    By this I’m guessing that you mean that DSS would start doing PSIs again? When DSS stopped doing PSIs and OPM took over, didn’t a bunch of investigator positions transfer over to OPM? So if DOD/DSS started doing them again, would it be a safe bet that positions would transfer back?

    “…or that all Investigators will be contractors so who knows”.

    Has that actually happened in the last 10-15 years, where GS investigator positions were eliminated and replaced with contractors?

    “The successful investigators look at the job as a service, you work nights and weekends to accommodate others schedules as needed.”

    It’s funny you mention that; I remember it used to be the policy that you couldn’t work past 6PM without getting special permission. Heaven help you if you got in any kind of accident after that and hadn’t pre-cleared it. Do you guys have to do the MARs (Monthly Activity Reports), or was that strictly a DSS thing?

    “You also have to learn to roll with the punches, you’re asking for information from sources, with no real authority, so your people skills have to be superior, there is no way around it”.

    That’s actually one of the things I really miss about the job. I know a lot of people who look down on PSIs as mindless grunt work, but I always had a lot of fun with it. I got to see all kinds of different businesses and talk to a bunch of different people. I hate hate hate sitting at a desk all day.

    Fed, thanks for your insight.

  23. Avatar


    If you are considering leaving another fed. govt agency for OPM to do BI’s than you are definitely on the right threat now,… Question 21 (mental health). 🙂

  24. Avatar

    sorry, typo… right thread now,…

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    It wouldn’t be the first time I’ve been so accused… 🙂

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    The rumors Ive heard about Investigators being turned into contractors or DOD taking back over are just rumors. There is. Bitter taste from the old guard Investigators about OPM taking over. I cam on in the first hiring wave like six years ago and heard lots of complaints in regard to the DSS days vs. OPM’s way of doing things.

    The job is stressful at times, like now, Ive been so busy interviewing, I have several large cases that need to be typed so Ill be typing this weekend, which sucks but it all washes out in the end.

    I can not imagine working this job 9 to 5. Youre still supposed to get permission to have the GOV out nights and weekends but its just another part of life at this job.

    I love the job 90% of the time, which is a pretty f*cking good percentage in my book.

  27. Avatar

    Excuse the typos, Im on a crappy tablet thing thats hard to type on.

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    Shelia, I may have missed someone else suggesting this to you, but if not I would recommend that you obtain a copy of your report as well. I am also sorry for how that investigator interrogated you, it sounds completely inappropriate.