The Defense Information System for Security (DISS) is a secure web application that allows security officials across DoD to communicate and record information regarding personnel security, suitability, and credentialing determinations.

DISS replaced the infamous Joint Personnel Adjudication System (JPAS) on March 31, 2021. This change – and DISS generally – was greeted with a yawn by most security clearance holders, the majority of whom may work their entire career without the system having any real relevance to their daily lives.

security clearance reciprocity and mobility – Key Tool Feautures

But the reality is even if you don’t have to access your security clearance information using the new system, your recruiters, security officers and hiring officials do – and adjustments to using the new system may mean more issues for security clearance reciprocity and mobility. When it comes to things like security clearance status, eligibility, and access, it’s not enough to simply let the system work – security clearance holders may need to reach out to verify their clearance status.

“If there is ever a question about status, the responsible Facility Security Officer can and should reach out to DCSA – VRO or CAS (Consolidated Adjudications Service, formerly CAF) – for a status update,” DCSA officials note.

Problem with Appeals for Some Clearance Holders

In addition to issues with status reporting for individuals who have their access to SCI denied or revoked, one reported problem involves civilian and military clearance-holders and applicants who are appealing an unfavorable DoD CAF decision to their respective Personnel Security Appeals Board with a personal appearance before a Defense Office of Hearings and Appeals (DOHA) judge.

In a multitude of such cases over the past year, the individual’s “Notice of Appeal” – the critical document that informs DOHA an appeal has been filed and places the individual’s case in queue for a hearing – has been lost somewhere in cyberspace between the local security official charged with uploading it to DISS and DOHA.

The problem hasn’t occurred in every case, but it’s occurred enough times that my office now makes a practice of confirming DOHA’s receipt of the Notice of Appeal in every single personal appearance case we handle. The obvious question is how many other clearance holders are waiting indefinitely – often while languishing on unpaid leave – for a hearing that will never come?  Also unclear is whether the issue is due to user error caused by a lack of training on the new system or a design flaw in the system itself.

stay Watchful for Issues with DISS

Until the problem is fixed or the personal appearance process is replaced with the appeals process currently in place for contractors (slated to occur by September 2022), anyone in such a situation should consider contacting DOHA to confirm that their case is in the queue for a hearing.

Similarly, FSO’s and SSO’s confronting a purported loss of collateral eligibility immediately after an unfavorable SCI adjudication should elevate the issue to DoD CAF senior management, as needed. We’ve seen a number of cases where frontline adjudicators have erroneously responded to FSO or SSO inquiries by claiming that access was “reciprocally” (i.e., automatically) denied or revoked by DoD CAF – something that is barred by DoD policy.  Don’t buy into these uninformed claims.

 

This article is intended as general information only and should not be construed as legal advice. Although the information is believed to be accurate as of the publication date, no guarantee or warranty is offered or implied.  Laws and government policies are subject to change, and the information provided herein may not provide a complete or current analysis of the topic or other pertinent considerations. Consult an attorney regarding your specific situation. 

 

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Attorney Sean M. Bigley represents clients worldwide in security clearance denials, revocations, and the security clearance application process. He is a former investigator for the Defense Counterintelligence and Security Agency (then-U.S. Office of Personnel Management). For more information, please visit www.bigleylaw.com. Readers will also find a low-cost, self-help option for obtaining copies of their security clearance background investigations and DISS/Scattered Castles records at www.bigleylaw.com/security-clearance-investigation-records.