The next two to three years will bring dramatic changes to the way personnel security investigations (PSIs) are conducted by the government. A pivotal role will be played by the National Background Investigation System (NBIS) currently being developed by the Defense Information Services Agency (DISA). NBIS, an investigative case control and management system, should be a vast improvement over the Office of Personnel Management’s (OPM) Personnel Investigations Processing System (PIPS) it will replace. Initially NBIS will support two Investigative Service Providers (ISPs)—the National Background Investigation Bureau (NBIB) and the Defense Security Service (DSS). Both NBIB and DSS will have multiple Investigative Units (IUs)—contractor and federal. In two to three years NBIB will become a part of DSS. Currently NBIB has five IUs, one federal and four contractors. By having many customizable features built into NBIS, other federal agencies that have authority to conduct their own PSIs will also be able to use the system. NBIS will enable rapid implementation of changes to investigative standards, as well as changes to each agency’s unique procedures for assigning and controlling cases.
The Benefits of Single Lead Assignments in a Security Clearance Investigation
NBIS will automate many tasks that are currently done manually by investigative researchers, field investigators and support personnel. It will have the ability to automatically divide up and assign individual investigative leads (an investigative lead is a single interview or record check) from single case to investigators working for different IUs. This could result in a full field investigation, like a Tier 5 for Top Secret clearances, being carved up into numerous pieces. Single-lead assignment will make it possible for small, regional contractors to provide investigative services to NBIB or DSS or any ISP, thus potentially increasing the overall number of IUs and the number of IUs conducting different leads on the same case. The following example depicts some of the standard field leads in a non-issue Tier 5 investigation for an applicant who has only lived, worked, and attended school in two neighboring cities in the Monterey, CA area during the period of coverage.
- Enhanced Subject Interview (ESI), employment reference interview(s) and employment record check, Monterey, Calif.
- Employment reference interview(s) and employment record check, Seaside, Calif.
- Educational record and educational reference(s), Seaside.
- Neighborhood investigation, Monterey.
- Neighborhood investigation, Seaside.
- Former spouse, Carmel, Calif.
- Social reference(s), Pacific Grove, Calif.
- Social reference(s), Marina, Calif.
- Police record check, Monterey.
- Police record check, Seaside.
Currently a case of this type would typically be assigned to one or possibly two investigators within the same IU—one who would conduct the police record checks and one who would do the rest of the case. Using automated single-lead assignment to the maximum practical extent, up to eight field investigators working for different IUs could be involved in this one case. In areas where police record checks are done by field investigators, up to ten investigators could be involved. The ability to carve up cases in this manner will result in greater efficiency by reducing the geographic area of responsibility for each field investigator and thereby reducing travel time between leads.
A secondary benefit of single-lead assignment is that fewer field investigators will be contacting the same companies, schools, and police departments. This will promote better relationships and cooperation between investigators and the entities they contact. Consider how disrupting it can be for a police department to have several different investigators coming to their office and submitting different name check requests on the same day, or for a company’s personnel office to have a few investigators lined up at their door waiting to do employment record checks on different cases. Having one investigator conduct employment record checks on five different cases at the same place at the same time is preferable to having five investigators conduct one employment record check each at the same location.
Downsides of Single-Lead Assignments
A downside is that responsibility for the quality of an investigation will be fragmented between several investigators, some of whom will be working for companies that are competitors. Without any sense of case ownership, field investigators will develop a “lead runner” mentality, concerned primarily with verifying information at one location before moving on to the next lead on a different case. Nuances detected in a reference interview or seemingly irrelevant anomalies in a record check, which might prompt an investigator to dig a little deeper in subsequent interviews and record checks, will be lost. Such information standing alone rarely goes into a report; it only provides background to inform the investigation as it moves forward.
NBIS will have multiple messaging channels for users (e.g. requesters, investigators, researchers, adjudicators, etc.) to communicate with each other. But the number of case messages investigators send to each other have never been factored into their productivity. Without an incentive, investigators will be disinclined to generate case messages and backchannel anomalous information to one another, particularly to an investigator working for a competitor at another IU. Some investigators, who work as subcontractors, are paid only for the number, type, and distance of the leads they complete. The performance appraisals of investigators who are paid a salary are based primarily on the number and type of leads they complete and the timeliness and quality of their reports. But report quality is measured in terms of pass/fail. If a report covers the required elements of information, it meets quality standards. Because of these performance goals, there is a disincentive to report more than the minimum required.
Increasing the Number of Expandable Focused Investigations
As automated record checks and cyber-vetting replace more standard field leads, field investigator will find that a larger percentage of their work will involve Expandable Focused Investigations (EFIs). EFIs occur when unfavorable listed or developed information triggers expansion of a case beyond the standard leads required for the investigation. Historically this occurs in about 25 percent of all cases—those with significant suitability or security issues. These cases need investigators, not lead runners.
There will be an inclination to use all the features of NBIS to the greatest extent possible to maximize efficiency, but single-lead assignment will need to be used judiciously. It may work well in all cases for field police record checks and other records where a copy of a relevant document, such as an arrest report, can be obtained and uploaded to NBIS. Individual EFIs, on the other hand, should be assigned to the smallest number of investigators possible within a single IU, and incentives should be created to promote the backchannel exchange of case information between field investigators.
Copyright © 2018 Federal Clearance Assistance Service. All rights reserved.
William H. Henderson is a retired federal clearance investigator, President of Federal Clearance Assistance Service (FEDCAS), author of Security Clearance Manual and Issue Mitigation Handbook, and a regular contributor to ClearanceJobs.com.