The Office of Personnel Management (OPM) is directing Federal agencies to begin continuous vetting (CV) procedures for employees in “non-sensitive public trust positions,” starting in fiscal year (FY) 2024.
Public trust positions typically do not require a security clearance, but they do require a background investigation to determine an employee’s suitability to hold the position.
In a memo sent to agency heads this week, OPM said continuous vetting will replace periodic reinvestigations to determine if an employee is suitable for the job.
“At this time, Federal agencies should begin considering how they will operationalize CV for this population, which would include, but is not limited to, tracking the population for enrollment, managing enrollment requirements, and managing CV alerts,” OPM said in a frequently asked questions document accompanying the memo.
“Agencies should work closely with their authorized investigative service provider (ISP) as they prepare implementation plans,” it adds. “Enrollment will proceed iteratively, with a goal of enrolling 100 percent of this population into an initial capability in FY2024.”
Once an individual is enrolled in CV, they will need to provide an updated personnel vetting questionnaire (PVQ) every five years. However, OPM said it hopes that soon “technology can support near real-time self-reporting data and annual updates such as through an Annual Vetting Appraisal (AVA) or other capability.”
The agency is currently looking into automation capabilities that would enable each individual’s vetting status to be continuously up-to-date, according to a proposed rule OPM published earlier this year.
The proposed rule follows along with the “Trusted Workforce 2.0” initiative, as well as President Biden’s 2021 National Security Memorandum.
Until that technology is available, the new continuous vetting guidance will apply to both Federal employees in the competitive service and in the excepted service, as well as Federal contractor employees.
The guidance builds upon a pilot program by the Defense Counterintelligence and Security Agency (DCSA), which initiated a continuous vetting program in June 2023 for the non-sensitive public trust population.
