Office of Personnel Management HQ, Washington, DC

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‘Continuous vetting’ effort will expand to cover more defense civilians

After a successful pilot program, the government plans expand the background-check process to all “public trust” positions.

Biden administration officials on Monday announced plans to expand the use of the new “continuous vetting” process for reviewing existing federal workers’ background checks to all “public trust” government positions by September 2024.

Part of an initiative dating to the Trump administration, continuous vetting refers to a new process by which the federal government uses automated data checks, such as credit histories and criminal records, to continuously monitor federal workers’ suitability to maintain a security clearance or otherwise serve in positions that require public trust.

It is designed to replace the existing process, known as periodic reinvestigations, and proponents hope the new process will ease some of the pressure that follow-up investigations place on the security clearance process, particularly the backlog of background checks required for federal job candidates to start work at their new jobs. Additionally, continuous vetting could catch potential red flags earlier, giving agencies a chance to offer support to federal workers experiencing difficulties before the problem can escalate.

Continuous vetting has already been implemented at national security agencies and for federal employees whose positions require a security clearance. And in a memo to federal agency heads Monday, Office of Personnel Management Director Kiran Ahuja, who works alongside the Defense Counterintelligence and Security Agency on federal background checks for current and prospective federal employees, said OPM and DCSA hope to roll the new process out to all federal workers in “public trust” positions by the end of fiscal 2024.

“DCSA...initiated a continuous vetting pilot in June 2023 for the non-sensitive public trust population,” she wrote. “Full implementation of this population is currently targeted to begin in fiscal year 2024. Enrollment will proceed iteratively, with a goal of enrolling 100% of this population into an initial capability in fiscal 2024.”

Although continuous vetting will replace periodic reinvestigations, in the meantime, agencies should continue to begin periodic reinvestigations according to existing policy, Ahuja wrote.

“Until agencies begin enrollment of their non-sensitive public trust populations into continuous vetting, they must continue to initiate reinvestigations for individuals occupying these positions in accordance with existing policy and established protocol,” the memo states. “Doing so will ensure that agencies are in compliance with the regulatory requirement and avoid potential delays in mobility for applicants or employees caused by out-of-scope investigations.”

The move to continuous vetting will also take place for federal workers in the excepted service, as well as federal contractors and Defense Department non-appropriated fund employees. Agencies will be expected to respond to alerts generated by continuous vetting similarly to how they respond to alerts generated during the existing reinvestigation process, according to an FAQ document released Monday.

“Agencies should handle issue resolution in response to CV alerts much the same way as derogatory information discovered during a periodic reinvestigation is handled today,” OPM wrote. “Any result from a continuous vetting alert that meets the requirement for expansion in Appendix I of the Federal Personnel Vetting Investigative Standards . . . will require the agency to request their [investigative service provider] to conduct the required investigatory actions. The agency will review the investigative results and make a suitability determination in accordance with Title 5.”