Federal regulation lists what a clearance adjudicator may do instead of issuing a Statement of Reasons. Direct further investigation. Send written interrogatories. Require a medical evaluation by a DoD Psychiatric Consultant. Interview the applicant. All four sit in one paragraph of 32 CFR Part 155, Appendix A, introduced as “interim actions”: the evaluation is filed beside the interview, not after the denial. The sentence above that list matters as much.

What does a referral to a clearance psychologist actually mean?

Short answer: Not a denial, and not nothing. The case reached this point because the clearance authority could not affirmatively find the clearance clearly consistent with the national interest. Regulation lists the evaluation beside interviews and interrogatories, an alternative to a Statement of Reasons rather than a consequence of one.

That sentence is paragraph 1 of the same appendix: “When the DISCO cannot affirmatively find that it is clearly consistent with the national interest to grant or continue a security clearance for an applicant, the case will be promptly referred to the DOHA.” The interim actions in paragraph 2 follow that referral. DoD applies the same logic department-wide, with the same predicate: paragraph 11.5 of DoD Manual 5200.02, headed “Post-Adjudication Issues,” reaches for a psychological evaluation “upon receipt of a report of adverse information from any source” that is “not adequate or detailed enough to make an eligibility determination.” Something was reported. Establishing what is the first useful move.

If instead the adjudicator concludes eligibility is not clearly consistent with the national interest, what issues is a Statement of Reasons, with its own clock and answer requirements. Knowing which letter you hold matters most. One caveat: Part 155 still carries its 1992 text as amended in 1994 and names offices, DISCO among them, long since folded into DCSA.

Who are the “security clearance psychologists”?

Short answer: A real, named government function. DCSA runs a behavioral science branch inside its adjudication and vetting services arm, and trains government-affiliated psychologists and psychiatrists for security-focused evaluations.

In the Defense Department’s October 2024 account, Michael Priester, a doctoral psychologist, is chief of that branch at the agency that adjudicates most industrial clearances. On who else may evaluate you the record is thin: SEAD 4 describes the clinician only as “employed by, or acceptable to and approved by” the government, and we found no roster of approved private practitioners. Do not assume your own therapist could serve.

What does Guideline I actually say?

Short answer: The ninth of thirteen adjudicative guidelines. It covers conditions that can impair judgment, reliability or trustworthiness, states that a formal diagnosis is not required, and bars inferring anything from counseling alone.

The operative text is Security Executive Agent Directive 4, effective 8 June 2017, which superseded all previous adjudicative criteria. The canonical PDF at dni.gov, cited here from an archived capture is an image scan, so the readable version is the codification at 10 CFR Part 710, Appendix A. Paragraph 27 closes:

No negative inference concerning the standards in this guideline may be raised solely on the basis of mental health counseling.

The same paragraph adds that a formal diagnosis is not required, and that a qualified professional should be consulted and a prognosis sought.

Now the part that cuts the other way, printed whole, because two of the five disqualifying conditions at paragraph 28 need no clinician’s opinion: 28(a) and 28(c). 28(a) is behavior casting doubt on judgment, stability, reliability or trustworthiness that may indicate a condition; the text names irresponsible, violent, self-harm, suicidal, paranoid, manipulative, impulsive, chronic lying, deceitful, exploitative or bizarre behaviors. 28(b) is an opinion by a duly qualified mental health professional that the person has a condition that may impair judgment, stability, reliability or trustworthiness. 28(c) is voluntary or involuntary inpatient hospitalization. 28(d) is failure to follow a prescribed treatment plan for a diagnosed condition, including failing to take prescribed medication or attend required counseling. 28(e) is pathological gambling, which surprises most readers.

So sit with 28(a) and 28(c): a history of self-harm or an inpatient admission can raise the concern on the record alone. Paragraph 27’s protection for counseling still stands, but the reassuring version of this guideline is one with two subparagraphs missing.

Paragraph 29 lists five mitigating conditions. 29(a) applies where the condition is readily controllable with treatment and the person has demonstrated ongoing, consistent compliance. 29(b) applies where someone voluntarily entered treatment and is currently receiving care with a favorable prognosis. Being in treatment sits on the mitigation side, weighed under the whole-person concept.

How often does this cost anyone a clearance? Rarely. DCSA’s October 2024 account reports 1,165 denials or revocations among more than 7.7 million cases reviewed from 2013 to 2023, none decided solely for seeking mental health care. Handle the figures carefully: DCSA also calls the psychological-health share “barely .01%” of denials and revocations, a base reconciling with neither number above, and no agency publishes a grant rate by guideline.

Why is so much clearance advice about mental health wrong?

Short answer: The superseded 1998 guideline is still printed in the CFR, and official federal pages still quote a version of the form’s mental health question the current SF-86 does not contain.

SEAD 4 has been in force since 2017, yet the old guideline remains codified at 32 CFR 147.11 and is still printed in the 2025 CFR. It is not current law, and it is materially harsher.

Counts taken by direct enumeration of the subparagraphs in each source text.

Stale text is not confined to the CFR. Military OneSource, a Defense Department site, publishes a page on psychological health and security clearance saying Question 21 asks whether, “in the last seven years,” you consulted a health care professional about an emotional or mental health condition. Checked live on 22 July 2026 it still says this; the current form asks no such question. Our thesis needs a qualification too, from OPM’s notice of 9 July 2026: applicants do not fill in the published PDF either, because the NBIS eApp is “the primary system used to collect this information.” Revisions approved in February 2024 and de minimis changes in May 2025 are in eApp but not in the PDF, which still tells applicants to lift a credit freeze, a requirement OPM says was dropped. Section 21’s text is unaffected.

What does the evaluation actually decide?

Short answer: Whether a condition impairs judgment, reliability or trustworthiness, not whether you have a diagnosis. The SF-86’s HIPAA authorization publishes the exact four questions a practitioner may be asked.

An applicant who answers “yes” in Section 21 signs an authorization letting the investigator ask their practitioner the listed questions and nothing else. Those four: whether the person has a condition that could impair judgment, reliability or trustworthiness; its nature and the extent and duration of any impairment or treatment; the prognosis; and dates of treatment.

The release runs one year from signature or until federal affiliation ends, whichever is sooner. Three qualifiers, all printed on the form, get dropped in most summaries. Revocation is in writing to the provider and “is not effective until received by my health care provider/entity.” It does not reach backwards: you may revoke “except to the extent that action has already been taken based on this authorization.” And the sentence calling it voluntary is HIPAA boilerplate about health care, not vetting; it promises only that “treatment, payment, enrollment in a health plan, or eligibility for benefits will not be conditioned upon” signing. Declining to sign is governed by Guideline E, below.

Section 21 also opens, in the government’s own voice, by stating that mental health treatment and counseling “in and of itself, is not a reason to revoke or deny eligibility” for access to classified information or a sensitive position, and that seeking care for personal wellness and recovery “may contribute favorably” to eligibility decisions.

Two further protections sit on the form and are almost never quoted. Under 21D: “any such diagnosis, in and of itself, is not a reason to revoke or deny eligibility.” Where 21E is answered yes, the follow-up about counseling carries an “I decline to answer” box and this note: “such consultation or treatment will not disqualify you and is considered to be a positive action.”

The five sub-questions are narrower than most expect: 21A a court or agency order declaring you mentally incompetent, 21B an order to consult a mental health professional, 21C hospitalization, 21D a diagnosis with any of seven named conditions. 21E is reached only if the first four are “no.” Mechanics: our walkthrough of SF-86 Section 21.

Can a psychological condition bar you from SCI or a special access program?

Short answer: Yes, through ordinary adjudication: an unmitigated Guideline I concern denies eligibility at every level, SCI and special access programs included. What no diagnosis triggers is the categorical statutory bar, which under the Bond Amendment is reserved for a person adjudicated mentally incompetent, reaches only SCI, special access programs and Restricted Data, and carries a waiver even there.

The statute is 50 U.S.C. 3343, and everything turns on “mentally incompetent,” which the statute and the directive define differently. Section 3343(c)(1)(C) reaches a person who “is mentally incompetent, as determined by an adjudicating authority, based on an evaluation by a duly qualified mental health professional employed by, or acceptable to and approved by” the government, and subsection (d)(2)(A) requires a means of appealing that determination. SEAD 4’s Appendix B is narrower: “declared mentally incompetent as determined by competency proceedings conducted in a court or administrative agency with proper jurisdiction.” Either way it is a formal determination by an authority, not a diagnosis and not a hospitalization. Readers who map it onto their own medical history, and readers who conclude a clinician plays no part, are both reading it wrong.

The waiver matters. Subsection (c)(2) permits an express written waiver in a meritorious case where mitigating factors exist, and SEAD 4 tells adjudicators to work the normal mitigating conditions first. Compare subsection (b), which bars any clearance for a covered person who “is an unlawful user of a controlled substance or an addict” and carries no waiver at all. Note the tense: that bar is keyed to current status, and nothing in section 3343 attaches consequences to what someone writes about past use, a separate question handled in our piece on the drug-use disclosure question.

What happens if you decline the evaluation?

Short answer: The refusal becomes the problem, and it lands under Guideline E rather than Guideline I, in the part saying refusal without reasonable cause will normally result in an unfavorable determination or cancellation of processing.

Refusal is not an ordinary disqualifying condition. Guideline E’s disqualifying list is paragraph 16, and refusal is not in it. It sits in paragraph 15, under a sentence of different force: “The following will normally result in an unfavorable national security eligibility determination, security clearance action, or cancellation of further processing for national security eligibility.” Item (a) is “refusal, or failure without reasonable cause, to undergo or cooperate with security processing,” naming completing security forms or releases and cooperation with medical or psychological evaluation alongside the subject interview. Keep both qualifiers: “without reasonable cause” and “will normally result.”

The Energy Department states the consequence precisely. Its rule at 10 CFR 710.6(a)(1) names “DOE-sponsored mental health evaluations” in the obligation to cooperate, then continues: “The individual may elect not to cooperate; however, such refusal may prevent DOE from reaching an affirmative finding required for granting or continuing access authorization. In this event, any access authorization then in effect may be administratively withdrawn or, for applicants, further processing may be administratively terminated.” Not automatic denial, but not limbo either. The counterweight is at 710.6(b): someone who believes paragraph (a) was applied inappropriately “may file a written appeal of the action with the Director within 30 calendar days of the date the individual was notified of the action.”

In the defense industrial programme, refusal to proceed can end in revocation, and a denied request to resume processing bars reapplication for one year. Guideline E paragraph 16(b) separately makes it disqualifying to deliberately mislead a “competent medical or mental health professional involved in making a recommendation.”

Frequently Asked Questions

Does seeking counseling by itself put a clearance at risk?

No. Paragraph 27 says no negative inference may be raised solely on the basis of mental health counseling, and the form itself says treatment “in and of itself, is not a reason to revoke or deny eligibility.”

Will my therapist be contacted, and what can they be asked?

Only if you answered “yes” in Section 21 and signed the HIPAA authorization, and then only four questions: whether a condition could impair judgment, reliability or trustworthiness; the nature, extent and duration of any impairment; the prognosis; and dates of treatment. Revocation must reach the provider in writing to take effect and does not undo disclosures already acted on.

Is a command-directed mental health evaluation the same thing?

No. DoD Instruction 6490.04 governs evaluations a commander directs for a service member, and its procedures do not apply to evaluations expressly required by a DoD issuance outside a commander’s discretion. The SF-86 draws the same line at 21B: an order by a superior officer is out of scope; an order by a military court is in.

Can a Guideline I concern get my clearance suspended while it is resolved?

Access can be affected while a concern is worked, a separate question from the eventual adjudication. What happens to pay and access during a suspension is covered separately, as is the other specialist-room experience in vetting.

The practical conclusion

Everything above that changes what a reader should do was found the same way: by opening the primary document and reading the subparagraph after the one everyone quotes. The two disqualifiers needing no clinician. The sentence putting refusal above ordinary disqualifying conditions. Summaries stop early, official ones included, and they stop where the reader’s decision changes.