One of the undeniable successes of Personnel Vetting reform has been the evolution of Continuous Vetting (CV). As part of Trusted Workforce 2.0, CV represents a shift from periodic reinvestigations to near real-time monitoring of cleared individuals, an approach designed to identify emerging risks as they happen, not years later.
That shift has been operationalized through increasingly sophisticated analytical capabilities: new threat indicators, expanding alert types, and a workforce trained to interpret complex data in a national security context.
CV isn’t just another task, it is the future of personnel security.
That’s why following the government’s continued efforts to implement CV are worth monitoring, as the road to modernized personnel vetting depends on modern CV.
CPOC 2.0, the follow-on Case Processing Operations Center contract, is DCSA’s next-generation acquisition vehicle intended to centralize and streamline support for personnel vetting operations. At its core, the contract combines traditional CPOC functions, which are largely administrative and case processing support for background investigations, with CV analytical operations under a single umbrella. The goal, at least in theory, is to create efficiencies by consolidating workloads, reducing costs, and enabling a more unified approach to managing the lifecycle of clearance-related activities. But by blending clerical processing functions with analytically intensive CV work, CPOC 2.0 represents not just a procurement shift, but a fundamental restructuring of how the government organizes and prioritizes its personnel security mission.
Redefining an Analytical Mission as Clerical Work
Early reviewers of the CPOC contract were concerned that rolling the CV mission into a predominately clerical contract may reduce a critical security and insider threat risk-based program into a largely clerical one.
In responses to vendor questions, the government stated there is no clearance requirement for CV personnel. That stands in contrast to current operations, where CV analysts require Top Secret eligibility and Tier 5 investigations to perform their duties effectively.
This isn’t a clerical shift, it’s a recharacterization of the work.
CV is not a clerical function. It requires analysts who can:
- interpret behavioral and financial risk indicators,
- evaluate threat data in context,
- and support adjudicative decision-making tied to national security.
From day one, the critical component of CV has not been the inputting of data, but how to qualify that data to ensure it is adjudicatively relevant.
The structure of the historical CPOC contract and its alignment under Service Contracting Act (SCA) wage determinations suggests a workforce model built around clerical labor, with a staff of various levels of “General Clerk” labor categories, not analytical expertise.
MITRE’s FAST (Federated Analytics and Security Transformation) study underscored the urgent need for DCSA to modernize its personnel vetting infrastructure. The study points to increasing data volumes, evolving threat vectors, and the growing importance of real-time, data-driven analysis as key drivers for transformation. It highlights that legacy, process-heavy approaches to vetting are no longer sufficient in an environment where risk signals emerge continuously and across disparate data sources.
Instead, MITRE emphasizes the need for scalable analytical capabilities, advanced automation, and a workforce equipped to interpret complex risk indicators. In that context, modernization isn’t just about efficiency, it’s about ensuring the system can keep pace with the threat landscape. Which raises a critical tension in CPOC 2.0: while the intent may be to modernize and streamline, the apparent de-emphasis of analytical rigor in CV risks moves the workforce model in the opposite direction.
Evaluation Criteria That Miss the Mission
DCSA’s justification for consolidating CPOC and CV centers on efficiency: cost savings, workforce flexibility, and operational streamlining.
The agency cites anticipated savings from relocating the workforce to Boyers, PA. Yet much of the CV workforce is already remote. The idea of cross-utilizing CPOC and CV personnel also runs into structural barriers. CPOC staff are governed by SCA labor categories, while CV analysts perform inherently analytical work outside those constraints. Cross-utilization is not simply a training issue, it’s a compliance and classification challenge.
Improving CPOC’s operational efficiency is a worthwhile goal. But emphasizing CPOC as a clerical function with an analytical addition runs counter to the Department of War’s efforts to turn personnel vetting into a mission critical function rather than a purely administrative one.
The Critical Question: Is Personnel Vetting Merely Administrative, or is It Mission Critical?
CPOC 2.0 was always going to be a consequential procurement. It sits at the intersection of modernization, mission delivery, and national security risk.
At a time when threats are becoming more dynamic, more data-driven, and more continuous, the current solicitation focuses on administrative functions, and exclusively as a small business set-aside, is likely to face major hurdles in the forms of protests and even congressional inquiry—efforts we’ve already seen.
The challenge for DCSA is aligning the acquisition strategy with the reality of a modern personnel vetting mission. The importance of CV across the personnel vetting enterprise which is central to the TW 2.0 policy framework cannot be overstated. A modern, agile CPOC 2.0 is a worthy effort, however, DCSA should rethink their position of emphasizing CPOC clerical SCA work over CV analytic work, including the clearance level of CV analysts, in support of a meaningful and mission appropriate CPOC 2.0 evaluation.
