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Everything You Need to Know About Continuous Vetting

Ryan Dennis, Deputy Assistant Director of Continuous Vetting within the Defense Counterintelligence and Security Agency (DCSA), joined us on a podcast episode of Security Cleared Jobs: Who’s Hiring and How to discuss the continuous vetting of security clearances. Read on to find out how the program impacts you as a clearance holder. You can also learn more from Ryan in his podcast appearance here.

DCSA has four major mission areas: personnel security; industrial security; training, education and certification; as well as national background investigation services. Under personnel security, DCSA delivers background investigations, continuous vetting and adjudications. 3.7 million clearance holders are enrolled in continuous vetting, representing the full enrollment of the entire cleared population.

Why Was Continuous Vetting Implemented

The concept of continuous evaluation began in the early 2000s, as an effort to bring automation to the security clearance process. Continuous evaluation really caught momentum after the unfortunate mass shooting at the Washington Navy Yard in 2013, when 12 members of our trusted workforce were killed, and three others injured. The need for continuous vetting was also portrayed by other events, including mass shootings at Fort Hood in 2009 and 2014, and a long line of individuals who have betrayed the trust bestowed upon them by the United States government.

The term changed from continuous evaluation to continuous vetting as standards were codified into law and policy. And the United States government began uniform implementation of continuous vetting under a trusted workforce. Trusted workforce is a personnel security reform initiative, which reduces the time required to bring new hires onboard, enabling greater mobility and improved insight into workforce behaviors.

What Exactly is Continuous Vetting

Continuous vetting is in place for the duration of time an individual is working on behalf of the United States government, in order to preserve the government’s confidence that the individual will continue to protect the people, property, information, and mission with which he or she has been trusted.

The continuous vetting process includes subscribing the clearance holder into a combination of perpetual, time-based or event-driven automated records checks, combined with information provided by the employing agency or company, and DCSA conduct of personnel security activities.

Continuous vetting replaces periodic reinvestigations with ongoing determinations of a person’s security risk. The ultimate goal of continuous vetting is to enable successful rehabilitation and retention of the clearance holder, so long as that is in the best interest of national security.

Is the Goal Really Rehabilitation

Depending on the position a clearance holder occupies, it can take months or even years to replace them at their job. That can have an impact on the mission readiness of our armed forces. The goal is to maintain trust – not perfection.

Our clearance holders are human. We all falter or fail at some point in our lives. And that doesn’t inherently make us untrustworthy. It’s our reaction to those failures that really matters.

Under the traditional model of periodic reinvestigations, once every five to 10 years, there was too much time or opportunity for a clearance holder to experience normal life stressors and suffer in silence. The person might be attempting to deal with those issues alone, but often unsuccessfully.

Rehabilitation in the context of continuous vetting means early identification and involvement. It means not letting the clearance holder have to guess what the government needs them to do in order to remedy the issue. It means giving them an opportunity to act responsibly early on, and with the help of assistance programs.

For example, once a year, a clearance holder’s credit bureau report will be evaluated. One of the most common events that triggers a continuous vetting alert is aggregated debt. It’s a clearance holder going more than 120 days without paying debts, which when combined, are valued at more than $20,000. When a continuous spending alert is provided, the clearance holder may not even be aware that this debt exists yet.

In other cases, perhaps they are all too aware. The delinquent debt could be the result of medical bills or loss of income within the household. Through continuous vetting and identifying this debt relatively early, it’s possible to provide the opportunity for the clearance holder to have resources made available, like financial counseling.

How Does Continuous Vetting Impact Me Directly

Everybody with a clearance is in continuous vetting. However, not much has changed for the average clearance holder. The clearance holder will continue to complete their SF-86.

Historically, the SF-86 has been done once every five to 10 years. It’s now required every five years to help ensure the accuracy of continuous vetting data checks, against information that changes, like names or addresses.

A very low percentage of clearance holders will actually generate a continuous vetting alert. If a clearance holder is made aware of an alert, it’s not the end of their career or clearance.

The clearance holder is expected to provide amplifying information. This involves explaining the circumstances surrounding the alert, what the person has done or is doing to act responsibly, as well as any documentation or records that person may have, which helps explain the situation. The more information the clearance holder provides at the onset, the quicker the continuous vetting alert will ultimately be adjudicated.

What’s Being Monitored and How Does It Work

There are seven categories that are monitored, including investigative and adjudicated records, criminal history, violent extremism, terrorism and unlawful subversive activities, financial history, foreign activities and associations, employment conduct, and interpersonal engagements. As part of completing the security clearance process, each subject provides consent to being monitored in continuous vetting.

DCSA has responsibility for enrolling the clearance holder by request of the employing company or agency into the required data checks. The data checks are run at a combination of subscription, time-based and event-driven frequencies. And then DCSA systems maintain a list of thresholds which will receive results returned from the various data providers.

Once DCSA systems determine a threshold is met, the system will generate what is referred to as a continuous vetting alert, which will then be presented to a DCSA continuous vetting analyst, to conduct alert validation. They will confirm the identity of the subject of the alert, verify that alert met investigative standard thresholds, and determine if the alert contains information which has not been previously evaluated in the security clearance process.

What Happens After an Alert is Validated

An example of an investigative trigger that meets a continuous vetting threshold would be misdemeanor arrests, warrants, or charges/convictions within the past five years. Again, a very low percentage of clearance holders actually generate an alert. But if a continuous vetting alert is generated upon you, your first notice of the alert will likely be via your security official, or a DCSA background investigator.

The format that you will be requested to provide information about the alert depends on several factors, including the severity of the alert information, like misdemeanors or felonies, as well as the position type and geographic location of the clearance holder.

The information could be scheduled to be discussed during an in person interview or a virtual interview with an investigator. It could be addressed with you through your security official. It might even be requested from you electronically.

Is It Better to Report an Issue Vs Being Notified

It’s not just better, it’s an expectation that the United States government has of all of its clearance holders. Obtaining and maintaining a security clearance is all about trust and acting responsibly. Being proactive and reporting information to your security official demonstrates that you understand the gravity of the trust the government has placed in you, and that you are willing and able to uphold that trust.

Also, remember the third step of the continuous vetting process, the alert validation process. Was the alert information already known? When a DCSA continuous vetting analyst sees self-reported information in a personal security system of record, there is no continuous vetting alert that would be generated, as the information is already being addressed. By self-reporting, the clearance holder is taking the fastest and most reliable path to resolving their issue and moving forward from that situation.

Security is always too much, until it’s not enough. The security clearance process is not fun, but it’s important. And if we think about it in context of what happened at the Washington Navy Yard and other events which have impacted people, property, information and missions, self-reporting and continuous vetting provide the best opportunity for early intervention.

Find more security clearance articles here.