The government will pay $4,460 for a single Tier 4 background investigation in fiscal year 2027. The same DCSA price list, Federal Investigations Notice 25-03, charges $455 for a Tier 3, the investigation behind a Secret clearance. Tier 4 costs nearly ten times as much, and produces no clearance at all.

Tier 4 is the high-risk public trust investigation. Candidates rarely know that, and recruiters mis-tag reqs because of it: the posting says cleared, the paperwork says SF-85P, and the applicant pool shows up wrong.

Public trust and security clearance are not two rungs of one ladder. They are two separate measurements taken on the same job.

What is a public trust position?

A public trust position is a job that federal regulation designates at the moderate or high risk level. The designation measures how much damage a bad hire could do to the integrity and efficiency of the service. It says nothing about classified information.

The rule is 5 CFR 731.106. Agency heads must designate every covered position at high, moderate, or low risk, and subsection (b) does the naming: high or moderate risk equals public trust. Risk in, label out.

The duties that pull a job upward are named: policy making, major program responsibility, public safety and health, law enforcement, fiduciary responsibilities, control of financial records. Nothing about classified material. The concern is fraud and institutional damage, not espionage. And 731.106(a) reaches contractor employees explicitly, which is why public trust reqs fill the cleared job market without a clearance in sight.

Why is a public trust position not a security clearance?

Because risk and sensitivity are different designations under different regulations. Risk drives public trust under 5 CFR 731.106. Sensitivity drives national security eligibility under 5 CFR 1400.201. Every covered position receives both. Only sensitivity can produce a clearance.

The regulation says it outright. Under 731.106(c)(2), any position subject to risk designation must also receive a sensitivity designation of Special-Sensitive, Critical-Sensitive, Noncritical-Sensitive, or Non-sensitive, and that designation is called complementary to the risk designation. Complementary. Not superior, not subordinate.

5 CFR 1400.201 maps sensitivity onto the familiar clearance levels. Noncritical-Sensitive covers Secret, Confidential and Department of Energy L access. Critical-Sensitive covers Top Secret and Q. Special-Sensitive covers Sensitive Compartmented Information and Top Secret Special Access Programs.

Then comes the asymmetry. Subsections (c) and (d) provide that a Critical-Sensitive or Special-Sensitive position automatically carries a high risk designation, and a Noncritical-Sensitive position a moderate one, both without further agency action. Read it backwards. Every Secret-cleared position is, by operation of regulation, at least a moderate-risk public trust position. It never runs the other way.

What are the five investigation tiers, and what does each cost?

Five tiers cover the current system, and the federal investigative standards crosswalk ties each to a form and a designation. T1 is low risk. T2 and T4 are the public trust tiers, on the SF-85P. T3 and T5 are the national security tiers, on the SF-86. Cost does not track prestige.

Tiers: CDSE Federal Investigative Standards crosswalk. Rates: DCSA Federal Investigations Notice 25-03, agencies outside DoD, effective October 1, 2026. Reinvestigation intervals as published by NIH for its own workforce; intervals vary by agency.

Two rows should stop a reader. A T2 public trust investigation costs exactly what a T3 Secret investigation costs. On the NIH schedule, a moderate-risk public trust employee is reinvestigated twice as often as a Secret-cleared one.

The five-tier model is on its way out. DCSA now sells a Trusted Workforce 2.0 three-tier structure as an Early Adopter service: $197 Low Tier, $845 Moderate Tier, $6,000 High Tier, while still offering the legacy five tiers through FY 2027.

How do the adjudication standards actually differ?

Suitability runs on eight factors today and ten from the end of this month, all of them ordinary employment concerns. National security eligibility runs on thirteen guidelines, which add a category the suitability factors never touch: foreign entanglement.

The list in 5 CFR 731.202(b) currently holds eight items: misconduct or negligence in employment, criminal conduct, intentional false statement or fraud in examination or appointment, dishonest conduct, excessive alcohol use without rehabilitation, illegal drug use without rehabilitation, acts designed to overthrow the government by force, and any statutory or regulatory bar. OPM’s final rule of June 30, 2026 adds two more on July 30: failure to meet financial obligations, and violent conduct.

Clearances are adjudicated instead against Security Executive Agent Directive 4, effective June 8, 2017, whose guidelines run A through M: Allegiance, Foreign Influence, Foreign Preference, Sexual Behavior, Personal Conduct, Financial Considerations, Alcohol Consumption, Drug Involvement, Psychological Conditions, Criminal Conduct, Handling Protected Information, Outside Activities, Use of Information Technology.

Lay the lists side by side and the hole is specific. Guideline B, Foreign Influence. Guideline C, Foreign Preference. Guideline I, Psychological Conditions. Nothing in the suitability factors, the current eight or the coming ten, reaches any of the three. A public trust adjudicator has no regulatory basis on which to weigh your relatives abroad, your second passport, or your mental health history. The July rule closes one older gap with a financial factor answering Guideline F. The foreign and psychological gaps it leaves untouched.

What does the SF-86 ask that the SF-85P does not?

The two forms are identical through Section 18, which covers relatives. Then they split. The SF-86 adds Foreign Contacts, Foreign Activities, Foreign Business and Professional Activities, Foreign Travel, and Psychological and Emotional Health. The SF-85P has none of those sections.

Section 19 is the fork. On the SF-86 it opens Foreign Contacts, 20A through 20C cover foreign activities, business and travel, and Section 21 takes psychological and emotional health. On the SF-85P, Section 19 is Foreign Countries You Have Visited and Section 20 is Police Record.

The gap in the form is the gap in the standard. Which is why the SF-86 runs 136 pages, the SF-85P 95, and the plain SF-85 fits in 18.

Both are filed through e-QIP or eApp, so the interface feels the same. The duty to be complete does not soften on the shorter form, and missing information is a well-worn path to denial.

How does continuous vetting change public trust?

It is replacing the periodic reinvestigation outright. 5 CFR 731.106(d)(1) now provides that continuous vetting for someone in a public trust position satisfies the requirement for a periodic reinvestigation of that individual.

The requirement traces to Executive Order 13488, signed January 16, 2009, which directed that people in public trust positions be reinvestigated on standards set by OPM’s Director. Seventeen years on, the regulation names continuous vetting as the substitute.

The rollout is uneven, and OPM says so. Its June 2026 rule notes that more than 4 million individuals in national security sensitive positions are enrolled in continuous vetting, with enrollment for nonsensitive public trust positions still underway. That is an enrollment count, not a census of cleared Americans.

The plumbing is arriving anyway. Starting in FY 2027, DCSA sells a Trusted Workforce 2.0 Phase 1 continuous vetting subscription for Non-Sensitive Public Trust enrollees at $6.95 a month, or $83.40 a year. Once an agency buys it, public trust status is monitored, not periodically audited.

Does a public trust investigation convert into a clearance?

No. A T2 or T4 is a suitability investigation on the SF-85P, and national security eligibility requires an SF-86 investigation. What it gives you is a reciprocity claim, worth real time when the next job sits at or below the same level.

Under 5 CFR 731.104(a), an agency must reciprocally accept a prior background investigation on promotion, reassignment, or transfer without a break in service, unless the new position sits at a higher risk level, and must accept an investigation at or above the level the new position requires. Trusted Workforce 2.0 formalizes the idea as named vetting scenarios, from Transfer of Trust to Reestablishment of Trust.

Do not plan a career around it. GAO reported in January 2024, in GAO-24-105669, that agencies lack reliable data on how often they honor previously granted vetting determinations, and that 28 of the 31 agencies surveyed said their IT systems sometimes lacked the information needed for reciprocity calls. Expect your prior investigation to help. Do not expect anyone to make it painless.

Which jobs are public trust, and what is the designation worth?

Public trust concentrates in civilian-agency IT, financial systems, program administration, and law enforcement support. As a credential it is worth less than a clearance, much more than nothing. It is a completed federal investigation, and hiring managers know what one costs.

The duty types in 731.106(b) predict the roles. Control of financial records puts accountants, auditors and financial systems staff in scope; major program responsibility catches program and contract managers. The administrators holding a civilian agency’s network keys are routinely designated high risk without touching classified material.

Pay proxies give the band, with the caveat that these are whole-occupation national figures, not public-trust-specific ones. The BLS May 2025 OEWS figure for information security analysts, the closest published proxy for cleared-adjacent cyber work, is a median annual wage of $129,180 across 190,650 people employed. Network and computer systems administrators sit at a $99,130 median on the same May 2025 vintage, accountants and auditors at $83,680.

A TS/SCI commands a premium a Tier 4 does not, because it is scarce and portable in ways a suitability determination is not. But the volume of civilian-agency contractor work needing public trust and nothing more is large, the competition thinner, the wait shorter. For a candidate with no clearance and no sponsor, it is often the fastest legitimate way into federal contracting.

So read the req twice. If it names an SF-85P, a Tier 2, or a Tier 4, it is a suitability position and no clearance comes out of it, whatever the title implies. If it names an SF-86, foreign contacts and psychological history are about to be on the table. The vocabulary will shift when the three-tier Trusted Workforce model displaces the five-tier one. The split underneath will not: risk on one axis, sensitivity on the other, one clearance at the end of it.

Frequently Asked Questions

Is a public trust position a security clearance?

No. Public trust is a risk designation at the moderate or high level under 5 CFR 731.106, based on the damage a position could do to the integrity and efficiency of the service. A clearance comes from a sensitivity designation under 5 CFR 1400.201. A cleared position is automatically also a public trust position, never the reverse.

What is the difference between the SF-85P and the SF-86?

The SF-85P is the Questionnaire for Public Trust Positions, 95 pages. The SF-86 is the Questionnaire for National Security Positions, 136 pages. They are identical through Section 18. The SF-86 then adds Foreign Contacts, Foreign Activities, Foreign Business and Professional Activities, Foreign Travel, and Psychological and Emotional Health, none of which appear on the SF-85P.

Does a Tier 4 investigation make it easier to get a Secret clearance?

It does not convert into one. National security eligibility requires an SF-86 investigation, which a Tier 4 is not. A favorably adjudicated investigation does support a reciprocity claim under 5 CFR 731.104(a) when you move to a position at or below the same level, though GAO found in 2024 that agencies cannot reliably measure whether reciprocity is honored.

How often is a public trust position reinvestigated?

NIH publishes a five-year interval for both Tier 2 and Tier 4 public trust positions, against ten years for a Tier 3 Secret and seven for a Tier 5 Top Secret. Intervals vary by agency, and 5 CFR 731.106(d)(1) now provides that continuous vetting satisfies the public trust reinvestigation requirement outright.

Can contractors hold public trust positions?

Yes. 5 CFR 731.106(a) applies the risk designation requirement to positions in which the occupant performs a service as a contractor employee, alongside competitive service, excepted service, and career SES positions. Public trust designations are common on civilian-agency IT, financial, and program support contracts.