I was surprised that the new (but not yet implemented1) Personnel Vetting Questionnaire (PVQ) does not ask for an applicant’s gender, height, weight, hair color, or eye color. Gender, height, and weight seem like relatively basic information that every background investigator should know about the “Subject” of an investigation.
It’s been my belief that knowing an applicant’s physical characteristics can be useful when trying to find and interview someone who knew Subject as a neighbor (neighborhood investigation). But since I haven’t done a background investigation in about 18 years, I visited the Investigators Forum at ClearanceJobsBlog and asked current background investigators.
The three people at the forum who responded said that these physical characteristics were very rarely useful or were simply unnecessary. That also surprised me. It might be that when I was first trained to do Special Background Investigations (SBIs), two neighborhood references had to be interviewed at each place of residence during the previous five years, and the clearance application form (DD Form 398) did not include the name and contact information for someone who could verify the residence. Today, the requirement for a Tier 5 investigation appears to be only one neighborhood reference at the most recent significant place of residence, and can be the person listed on the clearance application form (Standard Form 86) as the person who can verify the residence.
Here are partial responses from the forum:
Canvasing neighborhoods is the most distasteful part of the job. And yes, we never tell anyone what we know about a Subject, other than their name obviously. All else is off-limits.
I’ve never once used a secondary identifier in an investigation. And I would never tell a neighbor any of that info about a Subject.”
I’ve had Subjects who really don’t feel comfortable having their full name and age revealed to their neighbors.
These responses miss the point. Just because you have the Subject’s physical characteristics doesn’t mean you should disclose any of it to an interviewee. And asking an interviewee what their neighbor looked like, is pointless if you don’t know the Subject’s gender, height, weight, etc. These responses also suggest that if an investigator knows the Subject’s gender, they would never disclose or confirm it by using a personal pronoun like “he” or “she.” I have difficulty imagining a reference interview in which the investigator never uses a gendered pronoun when referring to the Subject or one in which the investigator uses gender-neutral pronouns. When the Department of Defense (DoD) switch from the DD Form 398 (Personnel Security Questionnaire) to the Standard Form 86 (Questionnaire for National Security Positions) in the mid-1990s, I reluctantly accepted that an applicant’s race would no longer be available on a clearance application form. Were these other physical characteristics removed from the PVQ because of a similar concern that they might evoke implicit biases of investigators or adjudicators?
Investigator: I’m conducting a federal background investigation on your former neighbor Morgan Taylor Mackenzie. “Ze” lived directly across the street from you until last month. Did you know zir?
Neighbor: Are you asking about Mack? I didn’t know his full name. I only knew him as Mack. He lived there with a woman, but I never knew her name. I got to know Mack pretty well, but not the woman.
Without knowing the gender of the Subject, it’s possible to get halfway through the interview before realizing that “Mack” is not the Subject of your investigation. Alternatively, you could choose not to conduct the interview due to lack of positive identification, and later find out that Mack is the Subject of your investigation. Perhaps it’s not important to investigators today, but I would be embarrassed if a potential reference suspected that I didn’t know the Subject’s gender. I agree that neighborhood investigations can be the most frustrating and least productive aspect of a full field investigation, but they sometimes produced information that would never be uncovered elsewhere. Perhaps such cases are rare, but they are the cases that really need to be fully investigated. And they are the ones where the Subjects’ physical characteristics could be important to the case. What if a neighbor, who lived directly across from the Subject’s listed residence, stated that she didn’t know any of the occupants’ names, but that all hours of the day and night there were visitors, who only stayed long enough for brief exchanges with one of the people who lived there.
Other Changes in the PVQ: Selective Service
The absence of a data field for gender on the PVQ was apparently not an oversight. The PVQ also has no question about Selective Service registration. On the current personnel security application forms (Standard Forms 85, 85P, and 86) the Selective Service question reads:
Were you born a male after December 31, 1959?
The absence of this question is notable, because failure to register with the Selective Service System, when required, can be the basis for an indefinite bar to federal employment. It can also be charged as a felony, even though it’s rarely prosecuted. Sure, the Government can check the Selective Service System for registration information using an applicant’s name, social security number, and date of birth, but what good is that when half of the checks will come back as “no record.” Will tens of thousands of “Subject Contacts” be conducted each year to ask applicants why they did not register for the draft? The obvious alternative is that the Government no longer intends to determine whether applicants are in compliance with the Military Selective Service Act (50 U.S.C. 3802). Allowing clearance applicants to withhold information about their gender may now be more important than determining whether applicants have complied with the law or making an investigator’s job a little easier.
Since at least 1995 Selective Service (SESE) registration checks were a standard component of all National Agency Checks (NACs) conducted by the Office of Personnel Management (OPM) for male applicants over the age of 18. However, SESE checks were not specifically required by federal security clearance investigative standards until the December 2012 Federal Investigative Standards (FIS) were approved.2 Security clearance application forms used by DoD prior to 1996 did not have a question regarding Selective Service registration, and SESE checks were probably not done on DoD security clearance investigations until 2005 when OPM took over doing background investigations for DoD. In March 2022 Federal Personnel Vetting Investigative Standards (FPVIS) for a new 3-tier system of investigations were approved, but have not yet implemented. Like the PVQ, the FPVIS has also been delayed due to problems with full implementation of the National Background Investigation Services (NBIS) system.1 It’s possible that the FPVIS does not require SESE checks, and the PVQ was developed accordingly.
There’s not much chance that physical characteristics will be added to the PVQ in the near future. Adding them to the PVQ would probably be considered a substantial change and would therefore 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.
1 The PVQ was approved by OMB in November 2023, but probably will not be fully implemented until sometime in 2027, because it’s implementation depends on the National Background Investigation Services (NBIS) system, which has experienced series of major problems and delays.
2 Based on a redacted version of the 2012 Federal Investigative Standards obtained in response to a Freedom of Information Act request.
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