Filling out the SF-86 application through the eQIP system is at times tedious, a virtual maze of drop-down boxes and prompts designed to neatly summarize an applicant’s recent life history. Nonetheless, the questionnaire demands precision in clicking those boxes and filling out those prompts.
In doing so, an applicant should take care in specifying the employer type under each employment activity, particularly for periods of self-employment. Why? That simple delineation in the employment section signals to investigators how to proceed in verifying the applicant’s employment.
For instance, when an applicant owns a business based out of his or her home, and the applicant filed a business license in his or her resident state, the investigator knows not to presumptively contact someone at the applicant’s residence in pursuit of an employment record. This may seem like a nuanced, if not moot point with respect to the application process, but correctly identifying the type of employment on an SF-86 aids in streamlining the investigation.
When to list
Self-employed applicants typically fit into either of two categories:
1) business owners/members — Be it a sole proprietorship, partnership. LLC etc. or
Independent contractor status is a legally significant distinction. Without exhaustively examining the definition of an independent contractor, the applicant should know whether his or her work classifies as self-employment. Certain odd jobs are cash-based, lacking the formalities and paperwork of traditional independent contractor positions. Nevertheless, the applicant should list such positions as self-employment where appropriate.
If your investigation calls for a personal interview with an investigator, be prepared to provide the relevant information at the time of the meeting. This may include the organization through which an applicant filed for a business license or a point of contact through whom the applicant signed a contractor agreement.
Who to list
Determining the best verifier for a self-employment activity varies depending on a number of factors: the nature of the work, the location of the work, and the duration of the work, among others. No hard and fast rule exists. As with any activity, the best verifier is typically the person with the most substantial and direct knowledge of the activity. In some instances this may be a client; in others this may be a partner or workload manager.
It is generally best to avoid listing subordinates or family members as a verifier, but in cases of small or family-run businesses, such people may actually be the most appropriate to list, absent the existence of a more objective verifier. In any case, the applicant should not list himself or herself as the verifier.
What to list
For a business owner who maintains a home-based business or who maintains a business at a standalone location, the standard procedure for traditional employment applies: the applicant should simply list the address at which he or she works.
For independent contractors, the best practice is not always so clear-cut. Because independent contractors are, by definition, their own employers, in many instances their homes may actually represent correct employment location. However, some may report to a specific job location each day, and the SF-86 should indicate as much by delineating between the home-address employer location and the job location. Others, such as contract investigators and consultants may rove among new locations each day, in which case the home address is the most appropriate employer location.
Whatever situation applies, it is important for the applicant’s SF-86 to reflect a centralized location, thus avoiding any confusion as to where the applicant’s personal interview may be conducted and ensuring the questionnaire is geographically consistent across activity sections (residence, education, employment). This is often a perfect opportunity to use the optional comments section for the purpose of clarifying any ambiguity arising out of an applicant’s listed self-employment.
