DPSAC News
A bi-weekly newsletter from the Division of Personnel Security and Access Control
Providing timely information to help keep NIH safe and secure

January 29, 2020 Issue of DPSAC News

 In this issue:
  • Using the Position Designation Tool - Step 2: Identifying Any Public Trust Duties
  • Be Sure to Respond to DCSA Requests for In-Person Interview if Contacted
  • FAQ: Whose Responsibility is it to Conduct Background Checks on Contractors Joining NIH?
  • Helpful Tips: Avoiding Additional Delays in Processing New Hires
  • AOs Who Wish to Obtain Sponsor Authority
Using the Position Designation Tool (PDT): Step 2- Identifying Any
Public Trust Duties
NED Release v.5.2 is tentatively scheduled for late March 2020. This version update will require the NIH administrative community to begin utilizing the Position Designation Tool (PDT) for determining the appropriate background investigation required for a position. As part of the lead-up to the NED Release, DPSAC and the NED Team will be communicating more details about these upcoming changes over the next several weeks.  

In Part I of this 5-part series on the updated PDT, the January 1, 2020 DPSAC News i ntroduced readers to this tool; Part II Step 1, January 15, 2019 DPSAC News , showed readers how to use the tool to determine whether the position being evaluated had any national security duties associated with it. In the current installment of the PDT series below, Part III Step 2, DPSAC News reviews how to use the PDT tool to identify public trust duties.

Part III, Step 2 of the PDT Tool -- Identifying Public Trust Duties
Every covered position must be designated at the low, moderate, or high-risk level as determined by the position’s potential for adverse impact on the efficiency and integrity of the service. 5 CFR 731.106(b) sets forth general categories of public trust duties and responsibilities.

The PDT expands upon those categories. Here, it is necessary to examine the position description and obtain any other supplemental information needed to fully assess the position duties and responsibilities to determine if they are public trust duties. Any/all categories that appear to be relevant to the position being evaluated, based upon review of the position description, etc. should be selected. 

Step 2 of the PDT is used to identify any public trust duties. Public Trust duties are indicated by checking the appropriate box (see selections listed below). For contractor positions, it is important to assess the duties the position will be performing for the Federal Government and not for the individual’s contract employer.

List of Public Trust Duties:

  • Government operations – rulemaking, policy, and major program responsibility (includes regulation or policy making, directing, implementing, advising and audits)

  • Public safety and health services, regulation, enforcement, and protection (Food safety and inspection, occupational health and safety, transportation safety, environmental safety and hazard mitigation

  • Law Enforcement or criminal justice duties

  • Protection of government funds for non-national security operations

  • Customs, Immigration, and/or Critical Infrastructure and Key Resources

  • Hazardous material handling and transportation

  • Physical security, controlling facility or physical access to information technology access, and/or controlled access to arms, ammunition, or explosives

  • Investigation, oversight, and audits of government personnel, programs, and activities

  • Adjudication of matters or claims (other than national security, suitability, fitness, or credentialing) with the potential to impact the public’s trust

  • Protection of government information technology systems (supervision or control of information technology systems, authority to bypass significant technical and operational security controls for general support systems, or access to major applications – the scope of these duties exceed that of ordinary or routine computer use)

  • Protection of personal, private, controlled unclassified, or proprietary information with the potential to damage the public’s trust (includes access to or processing of personal information such as that protected by the Privacy Act (PA) of 1974, exempt from disclosure under the Freedom of Information Act (FOIA), financial data, or privileged information involving the award of contracts, contractor proprietary information, etc.)

  • Government service delivery, including customer service or public liaison duties

  • Other activities demanding a degree of public trust [must describe the duties]

If any public trust duties are indicated as applicable with the given position, the level of damage that may be caused by the position must also be indicated. The degrees of potential impact are broadly defined. It is necessary to look at each public trust duty and evaluate the entire list of example duties provided to establish context to determine the scope of potential impact to the public’s trust. This reveals the potential damage to the integrity and efficiency of the service and the public’s trust. Users must select one of the following options:
Be Sure to Respond to DCSA
Request for an In-Person Interview if Contacted
Individuals hired at NIH for positions designated above Tier 1 should be aware that they may be contacted by a Defense Counterintelligence and Security Agency ( DCSA) investigator for an in-person interview. If you are contacted by a DCSA investigator, please make sure to respond to their call or email as soon as possible.

According to DPSAC, quite a few individuals being contacted by DCSA to participate in in-person interviews think these requests are a scam. Please be assured that these requests are a legitimate part of the investigative process. It is important that applicants respond to these requests. Not responding will result in an incomplete investigation and possibly having one’s physical and logical access to NIH deactivated until the requirement has been completed.
 
If you are contacted by an investigator who wants to arrange an in-person interview, but you are wary, you may ask the investigator for his/her badge number and confirm the person’s authenticity by calling DCSA at 1-888-795-5673 or emailing them at RMFSIMSST@nbib.gov. DCSA will be happy to confirm that the person is who s/he says s/he is.   Here is a link to the DCSA website with further instructions: https://www.dcsa.mil/mc/pv/mbi/vi/
Q . Whose responsibility is it to conduct a background check on a contractor who will be joining the NIH workforce?

A. As you know, there is a requirement for NIH FTE staff (employees) entering the NIH workforce to have their fingerprints and e-QIP fully completed before they can come on board at NIH.
 
For contractors, the NIH requirements for background checks extend over and above the contracting company’s responsibility to prescreen their hires. If NIH-conducted fingerprints or background check requirements are still pending when the contractor starts work for the contracting company, they are completed once the individual is on site, or earlier if the opportunity is available. In some cases, when contractors are far removed from an NIH campus they can request fingerprint cards that can be completed at a local police station.

Please note that in these instances, the contracting company is at risk if the individual is not able to fully complete these requirements successfully.
Avoiding Additional
Delays in Processing
New Hires

Processing times are often delayed due to reasons outside of DPSAC control, which include, but are not limited to:
  • Incomplete or not submitted OF-306
  • Candidate response time
  • Issues requiring classification by the candidate
  • Untimely submission of initial e-QIP or corrected e-QIP

How the AO and HR communities can assist:
  • By ensuring all required documents have been uploaded into HR's 'Onboarding Manager' prior to establishing a NED account
  • By entering candidates as early as possible but no later than 8 weeks prior to their Entry on Duty(EOD) date
  • By working with DPSAC to ensure candidates respond in a timely manner to inquiries

ALT cards -- should be returned to the  IC ALT card coordinator - NOT to DPSAC.
Administrative Officers (AOs) who wish to obtain sponsor authority must complete the sponsor training. To access the training module, click on: Sponsor .

Upon completion, the AO should sign and email a copy of the certificate found at the end of the training module to Alex Salah at: salaha@ors.od.nih.gov . Upon receipt of the certificate, Mr. Salah will authorize the AO as a Sponsor. 

Note: ONLY individuals with an Administrative Officer role in NED are eligible to be HHS ID Badge/PIV Card Sponsors.  
Are there topics you would like to read more about in future issues of DPSAC News?
Please send your suggestions to: Lanny.Newman@nih.gov . Your input is greatly appreciated.
A biweekly e-newsletter from the National Institutes of Health, Office of Research Services, Division of Personnel Security and Access Control (ORS/DPSAC) to keep its readers informed of personnel security and access control policies and practices designed to safeguard the NIH and its workforce. DPSAC is responsible for verifying personal identity, validating suitability, reviewing background checks, authorizing facility access and issuing ID badges for NIH personnel. 

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