The government continues to move forward with its massive overhaul of the personnel security program, Trusted Workforce 2.0. In September, the government completed its enrollment of the national security workforce into its Trusted Workforce 1.5 continuous vetting capability. Trusted Workforce 1.5 includes seven different automated checks, and allows for the replacement of periodic reinvestigations.
The move to a continuous versus episodic model of establishing ongoing clearance eligibility doesn’t replace the need for security clearance holders to report potential adverse information, however. Self-reporting requirements remain on the books, and have been updated in recent years through Security Executive Agent Directive (SEAD) 3, which codifies security clearance reporting requirements and emphasizes the need to inform about potential issues rather than waiting for an investigation to be triggered.
Despite self-reporting requirements, government officials acknowledge the majority of issues were not previously reported. Of the approximately 190,000 continuous vetting alerts received by the Defense Counterintelligence and Security Agency in FY 2022, well over half (approximately 110,000) were issues that were not previously known.
Criminal and financial issues are the most valid alerts triggered under CV, noted Mike Ray, Vetting Risk Office at DCSA, speaking at a recent meeting of the National Industrial Security Program Policy Advisory Committee (NISPPAC). “The goal is to have individuals self report,” he emphasized.
What to Report?
The issues that need to be self-reported in many ways align with the adjudicative guidelines – with some variance. Specific issues that need to be reported to a security officer include:
- Foreign Activities (application for or receipt of foreign citizenship, or a foreign passport)
- Attempted elicitation, blackmail, or coercion
- Media requests for classified information
- Arrests
- Bankruptcy or delinquency of debt for more than 120 days
- Alcohol and drug related treatment
Top Secret security clearance holders have additional reporting requirements, specifically:
- Foreign Affiliation; voting in a foreign election
- Personnel Finance and Business Anomalies; financial anomalies
- Personnel Finance and Business Anomalies; direct involvement in financial business
- Personnel Finance and Business Anomalies; foreign bank accounts
- Personnel Finance and Business Anomalies; ownership of foreign properties
- Living Status/Arrangements; cohabitation
- Living Status/Arrangements; marriage
- Living Status/Arrangements; adoption of non-U.S. citizen children
- Living Status/Arrangements; foreign national roommates
It’s worth noting what doesn’t need to be self-reported – specifically mental health treatment. For years the national security community has tried to reduce the stigma around seeking mental health treatment. Those in positions of public trust don’t have anything to fear from seeking proactive mental health treatment, and properly treated mental health issues almost never result in security clearance denial or revocation.
What Could Cost You Your Clearance
Reporting on top causes of clearance denial and revocation for FY 2022 for Department of Defense/Industry security clearance holders and applicants, DCSA noted the following:
Personal conduct becomes a factor for security clearance holders who either ignore or willfully violate current self-reporting rules. Like reducing stigma on mental health, the government is working to reduce the stigma of reporting potential issues, and emphasizing how being proactive in addressing issues – whatever they are – is the critical piece to maintaining clearance eligibility.
Trusted Workforce 2.0 is about ushering in a new culture of trust, girded by technology. CV and self-reporting are a representation of that marriage of technology and personal accountability. Just like the vast majority of security clearance applications result in a final successful determination, the vast majority of alert issues can be mitigated. What is difficult to mitigate for either a current security clearance holder or applicant is the failure to disclose an issue. Prior to CV, that failure may have been mitigated over time, even with a failure to properly self-report. But thanks to CV, issues can no longer hide within a five-year interval. And as Trusted Workforce 2.0 becomes fully implemented, the need to self-report will become the critical piece for a clearance holder with an issue – whether it’s the need for drug treatment or financial issues – keeping their eligibility.
