May is “Mental Health Awareness Month,” a good time to revisit the mental health question (Question 21) on the Standard Form 86 (SF86), “Questionnaire for National Security Positions.”  I wrote my first article about mental health and security clearance eligibility several years ago.   I also wrote a July 2013 article titled, “Changes to the Security Clearance Mental Health Question,” on the evolution of Question 21.

In the 2013 article I criticized the efficacy and relevance of the current version of Question 21.  I also felt that the Office of Personnel Management’s (OPM’s) proposed changes to Question 21 in their March 2013 60-day notice were poorly written and counterproductive.  I suggested that Question 21 either be eliminated or that the Defense Personnel and Security Research Center (PERSEREC) study the matter and recommend wording that might reliably capture useful, relevant information.

To mitigate some of the concern the Government would have in eliminating or narrowing the scope of Question 21 for military and contractor Secret clearance applicants, I suggested the Government completely replace the NACLC investigation with the ANACI investigation, which was better at surfacing secondary indicators of serious mental health problems and was only marginally more expensive at the time.  Apparently this had already been approved for initial Secret clearances, but was not implemented and made public until October 2015 with the introduction of the new Tier 3 investigation.

Clarifying Question 21

A few months after the SF86 60-day notice, OPM proposed new wording for Question 21 in their 30-day notice.  In March 2015 PERSEREC published a report on Question 21 in which it recommend significantly different wording.

The OPM 60-day notice proposed the following:

In the last seven (7) years, have you had a mental health condition that would cause an objective observer to have concern about your judgment, reliability, or trustworthiness in relation to your work? Evidence of such a condition could include exhibiting behavior that was emotionally unstable, irresponsible, dysfunctional, violent, paranoid, or bizarre; receiving an opinion by a duly qualified mental health professional that you had a condition that might impair judgment, reliability, or trustworthiness; or failing to follow treatment advice related to a diagnosed emotional, mental, or personality condition (e.g., failure to take prescribed medication). These examples are merely illustrative. Merely consulting a mental health professional is not, standing alone, evidence of such a condition. [Emphasis added]

The OPM 30-day notice proposed the following:

In the last seven years, have you had a mental health condition that adversely affected your judgment, reliability, or trustworthiness?

Did you receive counseling or treatment for that condition?  Merely consulting a mental health professional will not disqualify you.

Answering “yes” to these questions requires the applicant to provide dates of treatment and contact information for the medical practitioner who provided the counseling or treatment.  Other follow up questions regarding hospitalization, voluntariness of treatment, and court orders remain unchanged.  The first question proposed in the 30-day notice is only marginally better than the one proposed in the 60-day notice.  This threshold question still relies on the applicant’s self-assessment of their own mental health condition, and it’s questionable whether someone with impaired judgment can accurately assess their own condition.  Basically the question asks for an opinion, and as such the applicant cannot be held accountable for the accuracy of their response.   Neither version of the question will reliably capture the information that is being sought.

Making Mental Health Questions More Objective

The PERSEREC report, “A Relevant Risk Approach to Mental Health Inquiries in Question 21 of the Questionnaire for National Security Positions (SF-86)” (Technical Report 15-01) recommended more objective questions:

Have you ever been diagnosed by a physician or mental health professional with psychosis, schizophrenia, schizoaffective disorder, delusional disorder, bipolar mood disorder, borderline personality disorder, or antisocial personality disorder?

In the past 7 years, have you been hospitalized for an emotional or mental health condition?

The report does not suggest any follow up questions, if the applicant answers “yes” to either of these questions.  In fact the report recommends that clinicians who provided treatment should not be interviewed.  The report states:

“[T]he functions of fitness evaluation and treatment are fundamentally incompatible and should be kept separate. Psychological evaluation is one function psychologists perform and treatment is another. A psychologist (or other counselor) should not attempt to provide both functions for the same patient.  If a mental health assessment is required for purposes of a personnel security investigation, it should be conducted on behalf of DoD by a professional other than the treating therapist.”

Detailed persuasive arguments for their recommendations are presented in the report, including:

“‘True’ and ‘false’ answers to the proposed question leave little room for subjective interpretation and will generally be independently verifiable via investigation. . . . ‘Yes’ responses to the proposed revised question would carry meaningful implications for security investigations and could trigger psychological evaluations focused specifically on security risk.”

Clarifying Psychological Healthcare Relevance to Federal Investigations

However, the PERSEREC report does not suggest how false answers to the proposed questions can be verified through investigation, nor does it suggest what investigative actions should be taken when an applicant responds “yes” to either question.  The PERSEREC report implies that a “yes” response to their proposed questions may or may not require an independent psychological evaluation, so additional information would need to be collected by an investigator for that decision.  If the clinician who made the diagnosis is not going to be contacted, what information should the investigator obtain and from whom?  What circumstances would trigger a psychological evaluation?  The PERSEREC report fails to answer these important questions.

The purpose of Question 21 (and the other questions on the SF86) is to collect information to facilitate the conduct of Personnel Security Investigations, which will enable adjudicators to identify applicants who should not be eligible for security clearance.  It’s not enough to merely recommend new wording for Question 21 that focuses “only on standardized clinical conditions that could pose a security risk as well as mental health related hospitalizations.”  It’s necessary to explain how the answers to the proposed questions will be used.  By recommending that the clinician(s) who provided treatment for the applicant not be contacted and by not recommending an alternative source of information, the PERSEREC report does little to make Question 21 useful to the investigator or the adjudicator.

An alternative to interviewing the clinician would be to obtain a copy of their records and have those records reviewed by a Government mental health professional to determine if a psychological evaluation is required.

The questions proposed in the PERSEREC report are better than the questions proposed by OPM.  However for the PERSEREC questions to be more useful than no question at all, it will be necessary to either interview applicants’ mental health counselors or obtain their records to avoid having to conduct psychological evaluations on all applicants who answer “yes” to either question.

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William H. Henderson is a retired federal clearance investigator, President of Federal Clearance Assistance Service (FEDCAS), author of Security Clearance Manual, Issue Mitigation Handbook, and a regular contributor to ClearanceJobsBlog.com and ClearanceJobs.com.