While few security clearances or denied or revoked based on mental health issues, question 21 of the SF-86 continues to cause consternation for many security clearance applicants. The Director of National Intelligence hopes to change that with newly released guidance that makes it clear mental health treatment is not a detriment to holding or maintaining a security clearance.
In a memo signed November 16, Director of National Intelligence James Clapper notes the new S21 is adjusted to reflect that the fact of receiving treatment is not the central focus in asking about mental health, it’s “whether an individual has a condition that may affect his or her eligibility for access to classified information (security clearance) or for eligibility to hold a sensitive position.”
The new S21 asks specifically if the respondent has:
- been declared mentally incompetent by a court or administrative agency
- been ordered to consult with a mental health professional by a court or administrative agency
- been hospitalized for a mental health condition
- been diagnosed by a physician or other health professional with specifically listed diagnoses
- a mental health or other health condition that substantially adversely affects judgment, reliability and trustworthiness
A complicated solution to a simple problem?
As other contributors have brought up in the past, the issue of mental health in security clearance investigations is far from the top list of issues that cause clearance denial. The revised S21 is designed to clarify the criteria by which mental health issues will be reviewed. I doubt those clarifications will ease the minds of applicants who have ever been treated for mental health issues. Particularly because one of the more frequently asked mental health-related questions we receive at ClearanceJobs is what a respondent should list when they’ve received a diagnosis from a mental health professional but either disagreed with that diagnosis or refused treatment (is that an issue of trustworthiness and reliability or simply an issue of an individual expressing their right to disagree with a physician’s diagnosis?)
“Serious mental health conditions, not controlled by treatment, often surface in security clearance investigations due to conduct covered under other criteria in the Adjudicative Guidelines, such as criminal arrests, employment rule violations, financial delinquencies, drug and alcohol abuse, inappropriate behavior in the workplace, etc,” writes William Henderson, a retired federal investigator and the president of the Federal Clearance Assistance Service (FEDCAS). “The field portion of a Single Scope Background Investigation (SSBI) conducted for Top Secret clearances should have no difficulty identifying the existence of a serious mental health condition.”
The newly revised S21 is yet another step in the continued effort to take the stigma out of seeking mental health counseling, and put the focus on applicant suitability. But for a topic that’s still cause for anxiety for clearance holders with any mental health history, it remains to be seen if this step goes in the right direction, or simply results in more denied interim clearances and lengthy appeals processes.