The two sections on financial matters in the new (but yet to be implemented) Personnel Vetting Questionnaire (PVQ) have a few major changes from the forms currently used for federal personnel security programs:
- The look back period for all the financial questions have been reduced from seven years to five years.
- Applicant’s for low-risk/non-sensitive positions will no longer be asked to disclose failure to file or pay non-federal taxes.
- Applicant’s for low-risk/non-sensitive positions will no longer be asked to disclose past failure to file or pay federal taxes as required, if they file and pay the federal taxes before submitting their PVQ.
- Applicants for Public Trust and Sensitive National Security positions will no longer be asked specific financial questions regarding gambling, accounts referred to collection agencies, defaulted loans, and credit accounts that were suspended, charged off, or cancelled. All of these situations have always been adequately covered by the question that asks: “In the past five years, are you or were you more than 120 days past due on any debts?”
The PVQ was approved by the Office of Management and Budget (OMB) in November 2023 and will replace the Standard Forms 85, 85P, 85P-S, and 86. These Standard Forms (SFs) are used by people applying for federal employment, access to federal facilities and computer systems, Public Trust (PT) positions, and Sensitive National Security positions, including security clearances. The PVQ is currently being used on a very limited basis. Full implementation of the PVQ, which is dependent on the National Background Investigation Services (NBIS) computer system, is currently projected for spring 2026.
The approved final version of the PVQ has four parts (A, B, C, and D). These four parts in combination are roughly equivalent to the Standard Forms 85, 85P, 86, and 85P-S, respectively. Part A must be completed by all applicants. Parts A and B must be completed by applicants for PT positions. Part D is reserved for selected PT positions. Applicants for Sensitive National Security positions must complete parts A, B, and C. Each section of this multi-part form has threshold questions. If an applicant answers “yes” to a threshold question, they need to answer follow up questions, called branching questions. Some branching questions have their own follow-up questions. Three parts (A, B, and C) of the PVQ have questions related to financial matters.
PVQ PART A, SECTION 15—Federal Debt
Section 15 starts with definitions of “past due.” One of the definitions states, “You are not ‘past due’ if you were approved for a tax extension and you filed and paid your taxes by the extension due date.” This definition is contrary to Internal Revenue Service rules, which stipulate that you can get an extension to the due date for filing a federal tax return, but your taxes must be paid by the original due date.
Two of the threshold questions in Section 15 are:
Are there any tax year(s) within the past five years for which you have failed to file a federal tax return?
Have you failed to pay the amount due on your federal taxes for any tax year(s) in the past five years?
The SF85 has a question that reads: “In the last five (5) years have you failed to file or pay Federal, state, or other taxes when required by law or ordinance?” [emphasis added] The SF85P and SF86 have the same question but asks about the last seven years. The absence of the words, “when required by law or ordinance” in the PVQ makes a big difference. If an applicant files and pays their federal income taxes for the past five years any time before completing the PVQ, they could answer “no” to both of these threshold questions.
PVQ PART B, SECTION 23—Financial Record
Part B, Section 23 retains a non-federal tax question from the SF85P and SF86 without the words, “when required by law or ordinance”:
In the past five years, have you failed to pay any non-federal taxes?
Because of the absence of the words “when required by law or ordinance,” this question has the same limitation as the federal tax questions at Part A, Section 15. If you answer “no” to this question, you will not be asked the branching questions in Part B about the tax type, amount, year, filing date, and actions taken to satisfy the debt. Nor will you be asked the branching question at Section 23 of Part C. It’s notable that this question appears in Part B rather than Part A, since non-federal tax delinquency is currently covered in the SF85, as well as the SF85P and SF86.
Part B, Section 23 eliminates specific financial questions regarding gambling, accounts referred to collection agencies, defaulted loans, and credit accounts that were suspended, charged off, or cancelled. The following question, retained from the SF85P and SF86, adequately covers all of those situations.
In the past five years, are you or were you more than 120 days past due on any debts?
This question will also require applicants for PT and Sensitive National Security positions to disclose any instances in the past five years where they were more than 120 days past due in paying their federal and non-federal taxes.
Part B, Section 23 has a question regarding civil judgments, and Section 24 has a question about civil court actions. These questions ask:
In the past five years, have you had a civil judgment entered against you?
In the past five years, were you a party to any civil court action?
If you answer “yes” to the question about civil judgments in Section 23, you will have to enter all the details regarding the judgment, and you will have to repeat all this information plus additional information at the “civil court action” question in Section 24. The question at Section 24 makes the question about civil judgments in Section 23 completely unnecessary.
PVQ PART C, SECTION 23—Financial Record
The only financial question in Part C is a branching question based on an affirmative answer to the question at Part B about failing to pay non-federal taxes. This branching question asks:
Have you since paid these taxes in full?
This branching question serves no purpose, since it will only appear if you answer “yes” to the Part B question about failure to pay non-federal taxes. If you have paid the taxes in full prior to completing the form, you would answer “no” to the threshold question at Section B.
There are design errors, as well as some anomalies, in the PVQ. This appears to be true of Sections 01, 12, 13, 15, and 23. As mentioned in a previous article, there’s not much chance any changes will be made to the PVQ in the near future. In most cases changes to the PVQ would require full “Paperwork Reduction Act” processing. This would include a 60-day and a 30-day public review/comment period for the changes and final review/approval by the Office of Management and Budget—a process that takes several months.
Copyright © 2025 Federal Clearance Assistance Service. All rights reserved.
