Background Investigations

Written Inquiries Sent Out for a Background Investigation

The Office of Personnel Management’s National Background Investigation Bureau (NBIB) conducts background investigations for low risk non-sensitive, public trust, and national security positions for both civil servants and contractors working on behalf of the government. Some of the items on the Tier 1 through Tier 3 investigations may require completion of a form sent out by the NBIB to a person listed by the subject of the investigation. These forms may or may not get sent back in, it just depends on the diligence of the recipient. Here is a brief description of the forms used by NBIB:

General Request for Investigative Information (INV 40) – is used to collect records from a Federal or State record repository or a credit bureau.

Investigative Request for Law Enforcement Data (INV 44) – is used to collect law enforcement data from a criminal justice agency.

Investigative Request for Employment Data and Supervisor Information (INV 41); Investigative Request for Personal Information (INV 42); and Investigative Request for Educational Registrar and Dean of Students Record Data (INV 43) – these forms are sent to employment references, associates, and educational institutions. The forms disclose that the source’s contact information was provided by the subject to assist in completing a background investigation to help determine the subject’s eligibility for employment or security clearance, and request that the source complete the form to help in this determination.

All of these forms are currently undergoing minor tweaks in verbiage that will not change their intended purpose, but rather provide clarity to those filling them out. Additionally, soon to come is an updated Questionnaire for Non-Sensitive Positions (SF-85) for which NBIB solicited final comments to proposed changes last month. From what I can tell, two major changes of note are the addition of a Police Record section and the removal of the “people that know you well” reference section. This makes sense, as most of the time these do not get returned during the course of a low risk background investigation.

Discussion

  1. Marko,

    Of note: In the last few months, DHS HQ is sending out (per OPM/NBIB request) a (19 page) supplement to the SF85 for Public Trust-Moderate Risk (T2) Investigations.

    On a side note, why is the federal gov’t using the SF85 for T2/T4 Investigations as the positions are now considered sensitive…

  2. They use the SF-85P for Public Trust positions. The new supplemental questionnaire is not sent out, it is filled out by the applicants and submitted in lieu of having a subject interview on T2s.

  3. Marko,

    I am an FSO for companies that support DHS. In June/July OPM/NBIB directed DHS to send out the supplement to all in process T2s and send them to OPM. DHS now requires the supplement for all new T2 requests.

    My question about SF85P was in reference to the term “non-sensitive.” It appears as if the form is no longer appropriate for Moderate and High Risk “Sensitive” investigations.

  4. Exactly what I stated, the supplement is not sent out to anyone other than the applicant and then submitted. The other forms I noted in the article are sent out to other entities for return to OPM/NBIB. Regarding the form used, the SF-85P Questionnaire for Public Trust Positions instructions state it is used for eligibility for public trust or sensitive positions…

  5. Marko,

    Is there some type of internal timeout that OPM uses for the return of these forms? As in, if one of the references receives a form but never sends it in, how long does OPM wait around until they just move on with the investigation?

    Thanks

  6. The T2 Supplemental Questionnaire is only temporary until the SF 85-P is revised to include these expanded questions. As originally envisioned, the T2 would not have a PRSI unless certain triggers are present from the questionnaire. Going back to contractors and employees alike for this additional form has been a mess as well as balancing the OPM bill since those T2s have already been billed will now receive around a $1,000 credit for not requiring a PRSI.

  7. Agreed, it is a mess. We have tons of T2s that have been open for over a year waiting on the subject interview and now have to obtain and submit the questionnaire to OPM and have it reviewed before the investigation will get closed.

  8. @DcConsulter: In the joint Executive Agent memorandum published on June 5, 2018, Transforming Workforce Vetting: Measures to Reduce the Federal Government’s Background Investigation Inventory in Fiscal Year 2018, the PRSI for T2s was eliminated. The only reason a PRSI was being done was to ask the additional questions required by the 2012 Revised Investigative Standards which are now collected via written questionnaire. T4 and T5 level cases continue to have a PRSI.

  9. Thank you for the info!

  10. The T2 ESI has gone the way of the T3 ESI - The ESI is only conducted when there are specific reasons to conduct an ESI.