Understanding your position designation determination – (Non-Sensitive Low Risk vs. Public Trust vs. National Security Positions)
Amidst the numerous articles written by people with varying backgrounds, I have seen a lot of confusion generated about the types of federal contractor and civil servant positions and the investigative requirements for each. Having seen all sides of the process as a security clearance holder, background investigator, and investigation adjudicator, I thought I would try to simplify and clear up the misperceptions about types of positions, security clearances, and investigative requirements. “Position designation” is the starting point for determining the type of background investigation needed and when done properly, dictates how closely an individual is screened for a position.
A Non-Sensitive Low Risk position designation means that the employee is in a low risk position that does not have sensitive duties involving public trust or national security and does not need access to classified national security information (CSNI). These positions require the minimum level of background investigation be completed, in accordance with HSPD-12 requirements, in order to be eligible for unescorted access to federal facilities and/or IT systems. The minimum level of investigation is called a National Agency Check with Inquires (NACI) and it entails the completion of a National Agency Check (NAC), law enforcement checks, record searches, inquires of previous/current employment, education, residences, and references. The form used for this investigation is the SF-85 (Questionnaire for Non-Sensitive Positions).
A Public Trust position designation means that the employee is in a moderate or high risk position that does not have duties involving national security or needing access to CSNI, but requires a higher level background investigation due to the position’s other sensitive duties. These types of positions can vary and are designated based on their specific duties, e.g., security, investigations, fiduciary responsibilities, auditing, government policy or rulemaking, supervisory responsibilities, IT system administrators, and human resources personnel responsible for protecting sensitive information. A moderate risk position will require a Moderate Background Investigation (MBI) type of investigation while a high risk position will require a Background Investigation (BI). Both investigations require a personal security interview and the completion of a NAC, law enforcement checks, record searches, inquiries of previous/current employment, education, residences, references, and a credit check. For the BI some of these sources may also be interviewed in person. The form used for any Public Trust investigation is the SF-85P (Questionnaire for Public Trust Positions).
*Note– Public Trust positions may require the same level investigation as a national security position, but do not impact national security and/or require access to CSNI.
A National Security position designation means that the employee is in a low, moderate, or high risk position and has a need for eligibility to access classified national security information and/or is in a position whose duties are concerned with the protection of the nation and/or may have a material adverse impact on the national security of the United States. These types of positions require a national security background investigation. The term “security clearance” should only be used when referring to a national security position where someone needs eligibility for access to CNSI and the granting of a security clearance is needed. There are a variety of different types of background investigations used and it is dependent upon the position risk level and level of access needed, e.g., Secret, Top Secret. Some examples of initial investigations for national security positions are: ANACI, NACLC, MBI, BI, and SSBI. Depending on the level of the investigation, they may require a personal security interview, completion of a NAC, law enforcement checks, record searches, inquiries of previous and current employment, education, residences, references, and a credit check. For some of these investigations sources may also be interviewed in person. The form used for any national security investigation is the SF-86 (Questionnaire for National Security Positions).
*Note- Someone can be in a national security position but not be granted a security clearance. This is common-place within the Department of Defense. A security clearance is only granted based on need for access to CNSI.
Hopefully this article has helped to clarify the differences between low risk, public trust and national security position designations and the investigative requirements for each.