The security clearance process stayed on the move across 2021, with Trusted Workforce 2.0 continuing to make strides and major policy developments and reforms edging toward completion. What were the top trends of the security clearance process in 2021? Here’s a recap:
1. Continuous Evaluation.
We could probably just write Continuous Evaluation (CE) and Continuous Vetting (CV) five times and call it good. When it comes to the latest in the security clearance process, CE/CV is where it’s at. In October, the Defense Counterintelligence and Security Agency (DCSA) announced it had reached full enrollment into its CV program. That means all DoD clearance holders are continually vetted across three major criteria and the need for periodic reinvestigations as they were previously conducted (at episodic 5-6 or 10-year intervals) is over.
2. An Ever-Tightening Talent Pool.
If you know a recruiter in the cleared space, give them a hug – it’s rough out there. Demand for cybersecurity and TS/SCI cleared professionals continues to outpace the supply. Market trends of the past several years haven’t improved with faster clearance processing times – for many positions, poaching is the only way to find the talent with the magical secret sauce of skills, experience and clearance required for the contract. Unfortunately, the prevalence of telework and vaccine mandates for government contractors are tightening an already limited pool. A recent survey of cleared candidates by ClearanceJobs.com showed approximately 5% of respondents have no plans to get vaccinated. In an already tight market, a 5% reduction in personnel is significant.
3. SEAD 3 and New Self-Reporting Requirements
The implementation of CE has been a reminder that security clearance self reporting policies still exist – and the obligation of cleared professionals to still self-report is actually heightened by CV. It is better to report an issue to the federal government first rather than waiting for a topic to surface. SEAD 3 went into affect in August of 2021. In addition to clarifying foreign contact reporting requirements, as well as requirements for security clearance holders to report OTHERS who they know have a security clearance. It’s worth noting that Top Secret and Secret reporting requirements are different.
4. Marijuana, Cryptocurrencies, and Security Clearances
When it comes to external topics creating the most security clearance questions, marijuana easily tops the list. The continued roll out of ‘legal ‘marijuana use across more states has caused an uptick in the number of security clearance denials related to drug use. The legalization of drugs on the state level has made no change to federal law, so whether it’s being involved in a drug business or doing drugs yourself, if you want to maintain your security clearance, you have to just say no. Cryptocurrency is another area of policy change. After some ambiguity, DoD clarified in August via the NISPOM that foreign-held cryptocurrency should be reported.
5. NBIS and Technology Updates
The National Background Investigation Services (NBIS) is the next key step in security clearance reform efforts. It didn’t make headlines in 2021 – but we hope the background work done in 2021 will pave the way for NBIS to be the security clearance success story of 2022. NBIS is the heart of overhauling the legacy IT systems that continue to move cleared cases forward – and it’s also key to the transition from eQIP to eApp, and update that will improve the security clearance application process for the vast majority of applicants.
At the heart of all of the policy changes is the broader Trusted Workforce 2.0 effort. CE was the cornerstone of Trusted Workforce’s 2021 highlights, but expect NBIS updates and potential changes to adjudicative guidelines and other clearance policies to be on the docket for 2022. Reciprocity continues to be an issue, along with re-establishing trust in the workforce – how the federal government makes on and off ramps easier for cleared professionals.