Psychological conditions and neurocognitive disorders, such as Alzheimer’s disease or dementia, are not automatically disqualifying for a security clearance. However, they could raise concerns if they impair an individual’s judgment, reliability, or trustworthiness. Adjudicative Guideline I (page 19) of Security Executive Agent Directive 4 (SEAD 4) governs how such conditions should be evaluated in relation to an individual’s ability to safeguard classified, sensitive, or proprietary information.
These cases are often difficult because Guideline I (and agency adjudicators) usually focus on more recognizable psychological conditions such as Depression, Post-Traumatic Stress Disorder (PTSD), Bipolar Disorder, Schizophrenia, and other serious psychological disorders. While we have handled security clearance issues for people afflicted with neurocognitive disorders, the case law for these types of cases is pretty sparse. In other words, the security concern exists, but hasn’t really been developed in security clearance case law. We feel for these clients because they are going through significant medical issues and have to face potential security clearance concerns as well at the same time.
Neurocognitive Disorders Increase as Lifespan Increases
I foresee neurocognitive disorder security clearance issues arising more often in the future. People are living and working longer, and these types of health issues are likely going to arise more frequently. In a 2023 report, the RAND Corporation warned that dementia among clearance holders could pose inadvertent disclosure risks and represents a national security threat—but notes that no protocols currently exist to address this scenario. In my experience, this is accurate. Adjudicators are not presently focused on this issue.
Security Concerns Involving Neurocognitive Disorders
Major neurocognitive disorders such as Alzheimer’s or dementia (and other similar conditions) may (or may not) impair an individual’s judgment, reliability, or trustworthiness. Individuals with Alzheimer’s, dementia, or other major neurocognitive disorders may experience memory lapses, confusion, or diminished cognitive function that could lead to mishandling of classified information, difficulty adhering to security protocols, and inconsistent behavior.
These impairments could raise serious concerns when determining eligibility for access to classified materials. Even without a formal diagnosis, cognitive deficits that potentially impair judgment or reliability are reasons for concern unless mitigated. In many cases, individuals with these health concerns have been evaluated in an employment context and have been required to be assessed for fitness for duty. If deemed not fit, the employer generally takes another route (example: retirement). This happens quite often for federal employees. However, this issue could easily come up more often under Guideline I in a security clearance context.
Potential Mitigation for Neurocognitive Disorders
Given that there is not a lot of caselaw in this area of security clearance law, you would have to look at Paragraph 29 of Guideline I and analyze the specific medical issues of the neurocognitive disorder. The following factors could be considered when evaluating whether security concerns with respect to certain neurocognitive disorders have arisen:
- The condition is readily controllable, with consistent treatment compliance. Science is making significant strides with respect to Alzheimer’s and dementia, and it is likely that these conditions will end up becoming controllable with medical treatment now or in the near future. This would be a major mitigating factor.
- A recent expert medical opinion by a government-approved evaluator that the condition is controllable and unlikely to affect national security negatively. Much like a report on an individual’s diagnosis regarding Bipolar Disorder, an expert in neurocognitive disorders could evaluate the individual and issue a report stating that they are not a security risk or that their condition is stable.
- If the condition is temporary, resolved, and no current signs of instability remain. This remains possible, depending on medical advances. In the future, individuals with neurocognitive disorders might have them, but they could be curable. If so, this would be a significant mitigating factor.
- Other arguments could be made, such as one that the individual has remained stable with no issues. We could potentially have family members and friends submit statements on their behalf to attest to this.
For individuals with Alzheimer’s or dementia, mitigation may depend on early-stage diagnosis with stable functioning and ongoing interventions, such as cognitive stimulation therapy.
Final Thoughts
Security clearance decisions under Guideline I focus on whether an individual’s psychological condition may impair their judgment, reliability, or ability to properly safeguard classified information. Mental health concerns, such as neurocognitive conditions like Alzheimer’s or dementia should not be inherently disqualifying. However, they may raise concerns if they affect cognitive functioning or behavioral consistency.
If you are facing a security clearance review involving a psychological condition or cognitive health concern, you should seek experienced legal counsel familiar with federal clearance adjudications and security regulations.
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, regulations and government policies are always 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.
