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Hours: 8:00 a.m. - 5:00 p.m. Monday - Friday Personnel Security Helpdesk: 301-402-9755 E-mail: orspersonnelsecurity@ mail.nih.gov Access Control Helpdesk: 301-451-4766 E-mail: facilityaccesscontrol@ mail.nih.gov   |
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Your Position Sensitivity Level - the Starting Point in the Badging Process to Safeguard the NIH Workforce
This is the third in a series that explores Position Sensitivity Levels (PSLs) and their role in the vetting and protection of the approximately 37,000 employees, contractors and affiliates who are issued a Personal Identity Verification (PIV) card (a.k.a., HHS ID Badge) and become part of the NIH workforce.
Introduction
Every person entering NIH facilities is required to have an identification badge issued by DPSAC or the NIH Police. All federal employees, contractors and organizational affiliates who require access to federal facilities and/or information systems for a period greater than six months must complete the Personal Identity Verification (PIV)
[i]
process in order to be issued a PIV card (HHS ID Badge) or, in some cases, an NIH Restricted Local Access (RLA) Badge).
[ii]
As part of the PIV process, each position at NIH is assigned a level of risk and sensitivity that determines what type of background check will be required for that position.
While all employee, contractor and affiliate positions at NIH fall within one of three major security categories -- Non-Sensitive, Public Trust and National Security -- each position also has a defined risk and sensitivity profile that determines the type of background investigation that must be completed (Figure 1).
Figure 1
. The three main Security Categories and the Personal
Security Level(s) associated with them.
A Closer Look at Public Trust and its Level 5 and Level 6 Position
Sensitivity Levels (PSLs)
The first installment in this series (January 4, 2017 DPSAC News) offered an overview of the three main security levels along with a general discussion of the position sensitivity levels that fall within each of these categories.
The
January 18, 2017 DPSAC News examined in some detail the "Non Sensitive" security category and the single (and by far the most common) PSL at NIH -- Level 1 (Non-sensitive). The position title "Communications and Public Liaison Professional Staff" was used to demonstrate the scope of the investigation based on the Form SF85 background investigation questionnaire for a Level 1 (Non-Sensitive) position.
This installment examines the Public Trust security category and the Level 5 (Moderate Risk Level) and Level 6 (High Risk Level) PSLs that fall within the scope of Public Trust. For demonstration purposes, "Branch Chief" and "Division Director, NIH" will be used to illustrate Level 5B and Level 6 position sensitivity levels, respectively.
Applicants for Level 5 (Moderate Risk Level) and Level 6 (High Risk Level) PSLs are required to complete the Form SF85P background investigation questionnaire.
NED Registration
When an AO Sponsor begins the registration process for any new employee/contractor/affiliate in NED, s/he will need to select one of sixteen (16) position classifications presented in the drop down menu of the 'Classification' field. (Examples: NIH FTE-including GS, SES; Title 42, etc.; Contractor; NIH FTE - Commissioned Corps; Collaborator (Clinical); Collaborator (Non-Clinical); Guest Researcher; Fellow; etc.
For these examples, the AO will be selecting the classification field 'NIH FTE-including GS, SES.'
Also on that first screen, the AO will indicate whether the applicant is a Summer Student (N), whether the anticipated appointment time is more than or less than six months (more than six months), the SAC/Organization unit, and the position contact information (the name of the Supervisor and the Servicing AO).
On the following screen, the user will be prompted to fill out the online interactive worksheet (NIH Form 2866) that will calculate the appropriate sensitivity level and corresponding background investigation for a specific NIH position.
We'll be using the 'Branch Chief' position title on the worksheet to illustrate a Public Trust Level 5b (Moderate Risk Level) PSL. We'll subsequently use the position title "Division Director, NIH" to illustrate how to register a Public Trust Level 6 (High Risk Level) position in NED.
In both instances, the applicant will be required to complete the background investigation questionnaire Form SF85P in e-QIP.*
I. Calculating the PSL for a "Branch Chief" position according to the NIH Form 2866 worksheet
To determine the PSL for the 'Branch Chief' position using the NIH Form 2866, the AO will need to complete the following steps:
Step 1 of the worksheet prompts the user to select the Position Title from a drop-down menu. S/he will select "Branch Chief." If the user is not sure of the correct Position Title, s/he should contact the individual's supervisor.
Step 2 automatically validates the Position Sensitivity Level for the Selected Position Title/Function as a Level 5B (Moderate Risk Level).
Steps 3 in the worksheet allows the AO to select "exception factors" that require a minimum position sensitivity Level 5B. In this example, the AO selected three exception factors requiring a minimum position sensitivity Level 5B, namely: Step 3b: Performs Simplified Acquisition Certifications (Level 1) or higher procurement duties; Step 3d: Has approval authority for actions committing the government to a course of action involving financial and/or privacy act data (e.g., travel orders, personnel actions); Step 3e: Files Public Financial Disclosure Report (SF-278).
Step 4 in the worksheet allows the AO to select "exception factors" that would elevate the minimum sensitivity level to Level 2 PSL (Level 2 requires a higher level background investigation than Level 5B). In this example, the AO will leave Step 4 blank since there are no Exception Factors requiring a Minimum Position Sensitivity Level 2.
Step 5 asks the user to "Select Additional Exception Factors Requiring
No Position Sensitivity Level Changes." The only Exception Factor listed here is 'Works with children.' Applicants who work with children require additional scrutiny in their background investigation but will remain under Public Trust Level 5B. In this example, the applicant does not work with children.
The Position Sensitivity Level and Background Investigation for a "Branch Chief" position are revealed
Since the AO has determined that the applicant's position does not have exception factors to move him or her to a higher position sensitivity level or to an elevated background investigation, the NIH Form 2866 has computed the minimum position sensitivity level and background investigation at a 'Level 5 - MBI (Moderate Risk Background Investigation).
Note: When completing the NIH Form 2866 in NED, it is important never to guess! If you are not sure how to complete part of the form, DPSAC strongly advises you to reach out to the individual's supervisor. Be aware that DPSAC updates the NIH Form 2866 against the OPM Position Designation Tool (PDT) annually to ensure compliance.
e-QIP and the SF85P (the questionnaire for Level 5B and 6 Public Trust position investigations)
Once the AO completes sponsorship of the individual in NED, an applicant who needs to complete a background investigation will receive an e-mail from DPSAC with instructions to complete e-QIP (the Electronic Questionnaires for Investigations Processing) and any necessary forms.
Individuals whose position has been calculated via the NIH Form 2866 as Public Trust Level 5B (Moderate Risk Level) or Public Trust Level 6 (High Risk Level) will be asked to complete the SF85P questionnaire in e-QIP.
Note: If the individual does not complete e-QIP and submit the required forms, DPSAC will not be able to issue a new ID Badge to that person. This e-mail provides a secure link to e-QIP that allows the individual to access and complete his/her background investigation form online.
Access to the e-QIP system occurs only after the applicant has been sponsored for an ID badge in NED and has received his/her e-mail from DPSAC.
The scope and cost of the MBI investigation
MBI
(Moderate Risk Background Investigation) for a Public Trust Level 5b (Moderate Risk) position: includes a NACLC plus a Personal Subject Interview (PRSI) and written inquiries to employers, schools and references covering the past 5 to 7 years.*
(Note: t
he SF85P investigates the past 5 years but may be expanded to 7 years depending on the risk designation of the position.
Figure 2
below illustrates the additional requirements for an SF85P versus an SF85 investigation.
The cost of an MBI:
Once the NIH Form 2866 is complete, NED will also require a Common Account Number (CAN) to cover the costs of the background investigation. The FY'17 cost of an MBI is $1,515.
The FY 2017 OPM Pricing Schedule for the eight most commonly ordered background investigations at the NIH are posted on the DPSAC website at:
https://www.ors.od.nih.gov/ser/dpsac/bgchecks/Pages/pricing.aspx
II. Calculating the PSL for a "Division Director, NIH" position according to the NIH Form 2866 worksheet
Steps 1 and 2.
When the AO selects the position "Division Director, NIH" position in Step 1 of the NIH Form 2866, the worksheet automatically "validates the PSL for the position title as a Level 6 (BI) in Step 2.
Steps 3. For illustration purposes, the AO will select the same "exception factors" that require a minimum position sensitivity level 5b for Division Director, NIH as s/he did for Branch Chief in step 3, namely: Step 3b: Performs Simplified Acquisition Certifications (Level 1) or higher procurement duties; Step 3d: Has approval authority for actions committing the government to a course of action involving financial and/or privacy act data (e.g., travel orders, personnel actions); Step3e: Files Public Financial Disclosure Report (SF-278)
Step 4
in the worksheet for 'Division Director, NIH' is left blank since there are no Exception Factors requiring a Minimum Position Sensitivity Level 2.
Step 5
will also be left blank
, since the applicant again does not work
with children.
The Position Sensitivity Level and Background Investigation for "Division Director, NIH" are revealed
The NIH Form 2866 has computed the minimum position sensitivity level and background investigation at a 'Level 6 - (High Risk Level) Background Investigation (BI).'
The applicant will be required to complete the background investigation questionnaire, Form SF85P, in e-QIP. *
The scope and cost of the BI investigation
BI
(Background Investigation) for a Public Trust
Level 6 (High Risk) position:
includes an NACLC plus a PRSI; interviews at employment, schools and residences for the past 7 years, and review of any court actions for past 7 years. Figure 2 below illustrates the additional requirements for an SF85P versus an SF85 investigation.*
The cost of a BI (High Risk):
Once the NIH Form 2866 is complete, NED will also require a Common Account Number (CAN) to cover the costs of the background investigation. The FY'17 cost of a BI (High Risk) is $4,051.
The FY 2017 OPM Pricing Schedule for the eight most commonly ordered background investigations at the NIH are posted on the DPSAC website at:
https://www.ors.od.nih.gov/ser/dpsac/bgchecks/Pages/pricing.aspx
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Figure 2. Compares the scope of the SF85 questionnaire (for the NACI investigation) with the SF85P questionnaire (for the MBI/BI investigations). Note: the SF85P investigates the past 5 years but may be expanded to 7 years depending on the risk designation of the position.
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As part of the investigation process, the applicant will be asked to complete other forms in addition to the SF85P. At a minimum, s/he will need to complete the following:
- OF 306 (Declaration for Federal Employment)
- OF 612 (Employees and Affiliates) (Optional Application for Federal Employment)
- Any other required forms as directed in the e-mail
Acquisitions Professional
Administrative Officer (any grade)
Associate / Assistant Director (at the IC or major division level)
Associate Director, ORS and ORFDO (SES position)
Attorney, Office of General Counsel
Branch Chief
Budget (and Accounting) Analyst, Financial Management Analyst
CC Senior Management (e.g., COO, CFO, Chief, NPCS, Deputy, Associate & Assistant Directors)
Grants Management Professional Staff (Grants Mgmt Officer / Admin / Specialists)
Human Resources Management Staff (professional and support)
Immediate OD and EO office staff above GS-13
Immigration Specialist
Clinical Director, IC
Contracting Office Professional Staff (Procurement Analyst, Contract Specialist, etc.)
Deputy Director, IC
Dept. Head / Office Chief / Deputy Chief / Section Chief / Nurse Manager, CC
Deputy Scientific Director
Division Director, IC
Executive Officer
Financial Mgmt Office Professional Staff (Budget Analyst / Officer)
Firefighter, NIH
Lab Chief
Locksmith
Program Specialist
Purchasing Agent
Science Policy or Program Analyst / Leader
Scientific Director
Scientific Executive
Security & Emergency Management and Coordination Staff
Position Title / Function -- Sensitivity Level 6
CIO, IC
Deputy Division Director, NIH
Director, IC
Division Director, NIH
Emergency Dispatcher
ISSO and other IT Security Staff, IC
Police, NIH
To view more Level 5 and Level 6 positions listed on the 2866, please click
here
.
* Descriptions of the investigations referenced above:
NAC (National Agency Check)
-- an integral part of all background investigations, consisting of searches of OPM's Security/Suitability Investigations Index (SII), the Defense Clearance and Investigations Index, the FBI Identification Division's name and fingerprint files and other files or indices when necessary.
NACLC (National Agency Check with Local Agency Check with Credit)
-- NAC plus credit search and checks at local law enforcement agencies where
the subject has reside, been employed, or attended school for six months or more for the past seven years.
MBI (Moderate Risk Background Investigation) -- includes a NACLC plus a Personal Subject Interview (PRSI) and written inquiries to employers, schools, and references covering the past 5 to 7 years.
BI (Background Investigation) -- NACLC plus PRSI; interviews at employment, schools, and residences for the past 5 to 7 years; and review of any court actions for past 5 to 7 years.
PRSI - (Personal Subject Interview)
-- is conducted by federal investigators (Special Agents) and federal contract investigators (Special Investigators).
[i]
Personal Identity Verification (PIV) is a common credentialing and standard background investigation process required by Homeland Security Presidential Directive 12 (HSPD-12).
Certain classifications of individuals who are at NIH and who require access to NIH facilities will not require fingerprinting or a background investigation. These individuals will, however, undergo a standard criminal history check that will be conducted by the NIH Police prior to being issued an alternate NIH (Legacy) ID Badge.
[ii]
A PIV card is a United States federal smart card that contains the necessary data for the cardholder to be granted access to federal facilities and information systems and assure appropriate levels of security for all applicable federal applications.
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Update for Employees in Sensitive and Public Trust Positions,
Background Reinvestigations and Suitability
The following has been excerpted from the February 24, 2014 NIAID Director's Newsletter
The civil service requires high standards of integrity and trust. The federal suitability program was established to reduce the potential for abuse of the public trust. All individuals appointed to the federal service undergo a background investigation. Employees (and contractors and affiliates) in positions that are designated as sensitive, or one of public trust, are periodically re-investigated to ensure that they remain suitable for federal employment.
Failure to maintain suitability is grounds for termination. [In the past], individuals at NIH, and across the federal government have been terminated for this reason. There are new reform enhancements, increased oversight and greater accountability regarding the suitability program.
What are sensitive or public trust positions?
Based on the documented duties and responsibilities, these positions generally involve policy making, major program responsibility, public safety and health, law enforcement duties, fiduciary responsibilities and other activities demanding a significant degree of public trust.
These positions also involve access to operation or control of proprietary systems of information, such as financial records, and facilities with a significant risk for causing damage to people, programs or an agency. This includes unescorted access to restricted areas and buildings, the use of select agents and certain radioactive, biological or chemical materials and devices.
What is meant by suitability?
It refers to an individual's character, reputation, trustworthiness and conduct. It is used to decide whether or not an individual is "suitable" for federal employment, i.e., likely able to perform the duties of the position with appropriate integrity.
Suitability is different than qualification requirements of a job, such as experience, education, knowledge and skills.
Is a suitability determination the same as a security determination?
No. A security determination is made in addition to and after a suitability determination. They are separate and distinct determinations. A major difference between the two is that suitability considers only the individual's personal conduct while security concerns go beyond the individual's conduct to that of (for example) their associates or relatives, or the influence of foreign contacts.
When and what kind of periodic reinvestigation is performed?
Approximately every five years, individuals occupying a public trust level position are subject to re-investigation. Additionally, a re-investigation is performed when:
1. An individual moves into a position of higher risk and sensitivity than
previously held
2. New information (such as trouble with the law) calls suitability into
question
3. Conduct that is incompatible with core duties of the position
4. There is a break in service of more than 24 months.
The type of investigation varies and is dependent upon the risk and sensitivity of the position, and if appropriate, national security requirements. Each federal position is designated as having either a low, moderate or high risk level as determined by the position's potential for adverse impact on the efficiency and integrity of the service.
As the level of authority and responsibility of a position becomes greater, character and conduct become more significant in deciding whether employment or continued employment would protect the integrity or promote the efficiency of the federal service.
For entry into federal service, the minimum level of investigation is the National Agency Check with Inquiries (NACI). For positions with a risk designation, a NACI plus a Subject interview and a Background Investigation (BI) with five (or seven) year history of employment, residence and education is required.
What criteria are used to determine suitability?
Suitability determinations must be based on the presence or absence of one or more specific factors (changes). Only the following eight specific factors are considered a basis for finding a person unsuitable and taking a suitability action:
- Misconduct or negligence in employment
- Criminal or dishonest conduct
- Intentional false statement, deception or fraud
- Refusal to furnish testimony as required by 5 CFR 5.4 (Only OPM can cite this factor)
- Alcohol abuse, without evidence or substantial rehabilitation, of a nature and duration that suggests that the individual would be prevented from performing the duties of the position in question or would constitute a threat to property or the safety of others
- Illegal use of narcotics, drugs or other controlled substances without evidence of substantial rehabilitation
- Knowing and willful engagement in acts or activities designated to overthrow the US government by force (membership in an organization alone is not disqualifying)
- Any statutory or regulatory bar which prevents the lawful employment of the person involved in the position in question (must be specific legal restriction to employment)
Additional considerations, commonly referred to as the 'whole person concept,' are taken into account and may increase, reduce or possibly eliminate the resulting adverse action:
- Nature of the person
- Nature and seriousness of the conduct
- Circumstances surrounding the conduct
- The recentness of the conduct
- Age of person at the time of conduct
- Contributing societal conditions
- Absence or presence of rehabilitation or efforts toward rehabilitation
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FAQs
Q.
Why do I need a background investigation?
A. National security regulations require that all persons employed by the government shall be reliable, trustworthy and of unswerving loyalty to the United States. This means that the appointment of each civilian employee in any department or agency of the government is subject to investigation. The scope of the investigation will vary, depending on the nature of the position.
Q. I recently completed my e-QIP questionnaire and wanted to know whether I will receive a copy of my background investigation once it is completed?
A. When an individual's background investigation is completed, the individual will receive an e-mail from DPSAC's database letting them know the investigation is complete. For federal employees, their employee personnel file (eOPF) will be updated as well.
Individuals may request a copy of their investigation file under provisions of the Privacy Act. For an OPM investigation request, contact ORS Personnel Security (Phone: 301-402-9755; E-mail: orspersonnelsecurity@mail.nih.gov); or, write to OPM-CIS, FOIP, Post Office Box 618, Boyers, PA 16018-0618. You must include: your full name, Social Security Number, date and place of birth, and you must sign your request.
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Helpful Tips
Do not lend your ID badge to anyone! -- lending out your ID badge is prohibited. The issuance of ID badges is based on strict identity proofing and the determination of one's suitability for a specific position classification. To do so is a criminal offense.
ALT cards -- need to be returned to the IC ALT card coordinator -
NOT to the Division of Personnel Security and Access Control (DPSAC).
All Building 31 badging services -- Enrollment, Badge Issuance and Customer Service -- now offered at a single, convenient location in 1B03. All badging services in Building 31 are available between 8:00 a.m. and 5:00 p.m., Monday through Friday. DPSAC will continue to offer Enrollment and Badging services in the South Lobby of the Clinical Center from 7:30 a.m. to 4:30 p.m. on weekdays.
Administrative Officers (AOs) who wish to obtain sponsor authority -- must complete the sponsor training (see:
http://www.ors.od.nih.gov/ser/dpsac/Training/Pages/administrators.aspx) and e-mail a copy of your signed certificate to the NIH HSPD-12 Program Office at
hspd12@od.nih.gov. Upon receipt of the certificate, the Program Office will authorize the AO as a Sponsor.
Please note: ONLY individuals with an Administrative Officer role are eligible to be HHS ID Badge/PIV Card Sponsors.
ICs that want to add Lifecycle Work Station (LWS) operators to the approved roster -- send a written request to Richie Taffet at: taffetr@mail.nih.gov. Your request should include:
- the new operator's name
- his/her Institute or Center (IC)
- his/her NED number
- the operator's e-mail address, building/room and phone number
- the hours of operation of the Lifecycle Work Station
Once Mr. Taffet has approved the request, he will forward the name(s) to
HHSIdentityAdmins@deloitte.com to complete the approval process, add the name(s) to the LWS operator roster, and inform the IC that the individual is now approved to operate the LWS.
Need to make changes to the LWS operator directories? -- drop an e-mail to Lanny Newman,
newmanl@mail.nih.gov, and let him know what needs changing (e.g., adding new operators or LWS locations, removing operators, etc.). Remember, before a new operator can be added to the LWS directory, s/he must first be approved by Richie Taffet (see preceding Helpful Tip).
If an LWS is not available in your IC or your immediate area, and you work in the greater Bethesda or Rockville area -- please call 301-402-9755 to schedule an appointment with DPSAC, located in Building 31, Room 1B03 or in Building 10, South Lobby, Room 1C52.
If you work outside the Bethesda/Rockville area, contact your local badge issuance office. You can find contact information for all badge issuance offices at:
http://www.ors.od.nih.gov/ser/dpsac/Pages/contactinfo.aspx.
Know someone who should be reading DPSAC News? -- have the person contact Lanny Newman,
newmanl@mail.nih.gov, and ask to be put on the mailing list.
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NED Training Schedule for FY '17
Description:
This course provides an overview of the NED Portal and the NIH business functions it supports from the perspective of a NED Portal user with the AO or AT role. Upon completing the course, students will have a solid working knowledge of the NED Portal and be able to perform the following tasks: Register/Activate, Update, Modify, Transfer, Badge Renewal, and Deactivate.
The course will also familiarize students with other aspects of the NED Portal so they can: set their primary SAC coverage using Preferences; determine the status of a person's ID badge and/or network account request; look up and view information in a person's NED record; and, utilize NED reporting capabilities.
Intended Audience:
New or relatively inexperienced NED Portal users with the Administrative Officer (AO) or Administrative Technician (AT) role.
Prerequisites:
Basic personal computer skills and experience with web-based computer applications.
Reasonable Accommodations/Interpreting Services:
For deaf or hard-of-hearing individuals requiring interpreting services, please enter your request online in the Interpreting Services System at least five (5) days before the start of the class.
If you want to make a request, or have any questions regarding this service, you may contact the ORS Division of Amenities and Transportation Services (DATS) Interpreting Team at (301-402-8180). Individuals who need other reasonable accommodations to participate in any of the Center for Information Technology (CIT) Training courses should let CIT Training know at least 5 days prior to the class.
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A biweekly e-newsletter from the Office of Research Services, Division of Personnel Security and Access Control (ORS/DPSAC) to keep you informed as NIH rolls out "Homeland Security Presidential Directive 12" (HSPD-12) establishing a common identification standard to better safeguard NIH and its workforce.
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