Sitting in LOJ? The Reactivation Steps a New Employer Must Take to Re-Sponsor You

Posted by Ashley Jones

A loss of jurisdiction is a records action, not a verdict on your trustworthiness. When a cleared employee leaves a defense contractor, that company drops its relationship to the person’s record in the Defense Information System for Security (DISS), and the eligibility falls into one of three administrative states: Loss of Jurisdiction (LOJ), No Determination Made, or Administrative Withdrawal. Nobody adjudicated anything. No guideline was cited against you. Your clearance history simply has no owner. The two existing pieces on this blog cover what a loss of jurisdiction is and how it can stall a cleared career. This one covers the part they skip: the exact reactivation steps a new employer’s security office has to run to put your record back in service.

Key takeaways

  • LOJ is administrative. It is reversed by a Recertify Customer Service Request (CSR) filed in DISS, not by a Statement of Reasons, a hearing, or an appeal.
  • The load-bearing number is 24 months. Under a 24-month break in service the security office recertifies you; at or beyond it, a new initial investigation is required (DCSA DISS job aid, 2025).
  • Once submitted, a Recertify CSR is generally worked within 3 business days, and the security officer can check status at 4 business days (2025).
  • Under SEAD 7 (effective 2018), reciprocity is mandatory, but an agency may decline an investigation more than 7 years old.
  • None of it starts until an employer that holds a facility clearance takes ownership of your record (32 CFR 117.9, 2026).
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What does “loss of jurisdiction” actually mean?

LOJ ends your prior eligibility administratively when no employer holds your record. It is not a denial, a suspension, or a revocation. No one weighed a guideline against you. Your investigation and clearance history sit intact in the system of record, waiting for a new sponsor to claim them.

The reversal has a specific name. DCSA’s own DISS Customer Service Request job aid calls it the Recertify CSR, the request “created when a SMO requests recertification of a Subject who has lost their previous eligibility due to an administrative action.” That is the whole distinction. A revocation is a decision. An LOJ is an empty owner field. One is litigated; the other is refiled. If your situation is the first kind, this blog covers what a suspension or revocation involves separately, and the steps below do not apply to you.

Why can’t you reactivate your own clearance?

Because the fix is a record action inside DISS, and you have no account there. Only a Security Management Office, your new employer’s Facility Security Officer or security team, can take an “owning relationship” over your record. Without an employer that holds a facility clearance first, no one is authorized to file anything.

The mechanics are blunt. The company you left removes its relationship in DISS; the gaining company takes one. DCSA states it plainly: “the gaining SMO must take an owning relationship in DISS,” and “an owning relationship with the Subject is necessary to create a CSR.” That relationship is the gate, and everything else waits behind it.

There is a second gate above it. The employer itself has to be cleared. Under 32 CFR 117.9, neither a contractor nor its employees may access classified information “until the CSA has made an entity eligibility determination,” which is the facility clearance, or FCL. A company also cannot hand itself one. The rule bars self-sponsorship: “a contractor or prospective contractor cannot apply for its own entity eligibility determination,” and a Government Contracting Activity or an already-cleared prime has to sponsor it. That is why the reactivation question is really a hiring question. You need a company that can sponsor a clearance and an FSO who knows the DISS workflow. Finding one of the jobs that sponsor a clearance is the actual first step, not the paperwork.

What are the reactivation steps the new employer’s FSO follows?

Four moves inside DISS: take the owning relationship, confirm the break in service is under 24 months, confirm no case is already open, and submit the Recertify CSR. The determination posts back to DISS, usually within 3 business days.

In the order a security officer runs it:

  1. Take the owning relationship. The gaining SMO claims your record in DISS after the losing company drops theirs. No CSR can be created without it.
  2. Verify the break in service. The officer confirms there has been no gap of 24 months or more. If there has, this path is closed and step four must not happen.
  3. Confirm no open case. A Recertify CSR requires that “the Subject does not have an open case.” If a case is already open, the office uses a Supplemental CSR to request recertification instead.
  4. Submit the Recertify CSR. A Security Officer, Security Officer Admin, Security Manager, Component Adjudicator, or Application Admin files it. DCSA generally works the request within 3 business days, and the office may call the Call Center for status 4 business days after submitting.

The eligibility databases the officer touches are the same ones covered in Scattered Castles vs. DISS. For a clean LOJ with a recent-enough investigation, this is a days-long paperwork move, not a months-long re-investigation.

What is the 24-month rule, exactly?

Eligibility does not run out on a clock of its own. It stays intact as long as you have not gone 24 months or more without a cleared position. Cross that line and the Recertify CSR comes off the table; a fresh initial investigation is required.

This is the single fact most cleared workers get wrong, and it is worth stating precisely. DCSA’s DISS guidance says eligibility “does not expire so long as there has not been a 24-month or more break in service.” Read the emphasis carefully. It is a break in service, not a countdown from the day you were granted. Sit out fourteen months and get rehired, your eligibility was never at risk. Sit out twenty-five, and the officer is instructed: “If there was a two-year break in service, a new initial investigation must be initiated. Do not submit the CSR.” At that point you are back to submitting a fresh Standard Form 86, whose Section 16 alone asks for three people who know you well across at least the last seven years and who are not relatives or already named elsewhere on the form.

Staying inside the window is why continuous enrollment matters. A person kept in continuous vetting is, by definition, still in service. The same misread shows up when people leave the military and assume the clearance evaporated on a date. It did not. The clock that matters is the reactivation clock, and this blog’s breakdown of that clock walks the same 24-month line.

Recertify CSR or Request Reciprocity CSR: which path?

It depends on who granted the prior eligibility. If it came from DoD industry, the new FSO files a Recertify CSR. If another agency granted it, the FSO files a Request Reciprocity CSR instead, which needs the same owning relationship plus a check of Scattered Castles, OPM’s Central Verification System, and DISS.

The DCSA Reciprocity Guide is explicit about the cross-agency sequence: “ensure you have an owning relationship with the Subject to initiate the CSR,” then “conduct a review for the individual’s eligibility” in Scattered Castles, the Central Verification System within OPM, or DISS. SEAD 7 names the same systems of record, adding the DoD Joint Personnel Adjudication System “or successor databases.” The officer is not re-investigating anything at this stage; they are confirming a determination already exists, then accepting it. Here is how the two reactivation paths sit against the revocation path they are so often confused with.

  Recertify CSR Request Reciprocity CSR Statement of Reasons (revocation)
What triggers it LOJ, NDM, or Admin Withdraw on prior DoD-industry eligibility Prior eligibility granted by another agency Adverse adjudication of derogatory information
Who acts Gaining SMO / FSO Gaining SMO / FSO DoD CAF, then DOHA
Load-bearing number 24-month break-in-service cap 7-year investigation-age ceiling (SEAD 7) 20 days to answer; 15/45-day appeal
Governing source DISS job aid; 32 CFR 117.10 SEAD 7; DCSA Reciprocity Guide DoD 5220.6; 32 CFR 155 App. A
Nature Administrative restore Administrative acceptance Due-process litigation

One SEAD 7 nuance belongs here. Its auto-accept rule does not apply “when taking security sponsorship over the covered individual,” so a re-sponsor triggers a genuine reciprocity review, not a rubber stamp.

What does the NISPOM rule (32 CFR 117.10) say about breaks?

It separates a break in access from a break in employment. A current, in-scope investigation carries over with no new investigation. But if a break in employment caused a loss of eligibility, no access is allowed until the CSA makes a new eligibility determination.

The break-in-access provision is the friendliest text in the rule. If a contractor cut your access only because there was no current need for it, and you stayed in the company’s continuous employment, the contractor “may provide access to classified information without further investigation,” provided you remain eligible, hold a current in-scope investigation, and no new derogatory information is known. Break in employment is stricter. A contractor “may not provide access” to someone whose break “resulted in a loss of eligibility without a new eligibility determination by the CSA.” Reciprocity of a current eligibility bridges the two: an in-scope determination “will provide the basis for a new eligibility determination” and is used “without further investigation or adjudication unless the CSA becomes aware of significant derogatory information that was not previously adjudicated.” This is the governing text behind the 2026 NISPOM rule. One timing detail sits in the same section: a contractor may request an investigation before your start date only if employment “will commence within 45 days” of eligibility being granted.

Can you work on a temporary eligibility while the paperwork clears?

Sometimes. The CSA may grant temporary eligibility, the status formerly called interim, which “shall not exceed one year unless approved by the applicable CSA in the system of record.” For a new employer, it is the fastest route to putting you on the contract while the Recertify CSR posts.

That one-year ceiling is why temporary eligibility exists at all. The trade-offs are the same ones in this blog’s interim clearance explainer, whether the grant supports a first hire or a reactivation.

What if new derogatory information surfaces?

Then the path changes. Recertification and reciprocity both assume nothing new turned up. If something surfaced since your last adjudication, the adjudication facility re-examines it under SEAD 4’s whole-person standard, weighing nine enumerated factors. Only after that could the revocation machinery apply.

SEAD 4, effective in 2017, is the single common adjudicative standard and supersedes the older guidelines. Its whole-person concept weighs the nature and seriousness of conduct, the circumstances, the frequency and recency, your age at the time, how voluntary it was, evidence of rehabilitation, the motivation, the potential for coercion, and the likelihood of recurrence. Note what has to be true for that to even start: the CSA has to learn of “significant derogatory information that was not previously adjudicated.” Absent that, an LOJ never reaches this stage. If it does reach a Statement of Reasons, the clocks are entirely different. The written answer must reach DOHA “within 20 days from receipt of the SOR,” under oath, with a hearing specifically requested to get one. An adverse decision may be appealed within 15 days, with the brief due within 45. Those numbers describe due-process litigation. They have nothing to do with a Recertify CSR, and anyone who tells you an LOJ requires them is describing the wrong process.

Does winning the recompete re-badge you automatically?

No. There is no active federal right of first refusal today. The FAR clause that once created one, 52.222-17, Nondisplacement of Qualified Workers, is currently marked [Reserved]. A follow-on contractor has no automatic obligation to re-badge the incumbent workforce.

A lost contract does not hand you a seat with the winner. The reactivation still runs through a willing employer’s FSO, and the DISS workflow begins only after the seat is actually offered.

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Frequently Asked Questions

Is loss of jurisdiction the same as losing my clearance?

No. LOJ is one of three administrative actions (with No Determination Made and Administrative Withdrawal) that end your prior eligibility because no employer holds your record. It is reversed by a Recertify CSR, not by a hearing or an appeal.

How long does a Recertify CSR take?

DCSA generally works the request within 3 business days of submission, and the security officer may contact the DISS Call Center to check status 4 business days after submitting it. Those are the DISS job aid’s figures for a clean case.

What happens if I’ve been out for more than two years?

The Recertify path closes. DCSA guidance instructs the officer that if there was a 24-month or greater break in service, a new initial investigation must be initiated and the CSR must not be submitted. You would complete a fresh SF-86, whose Section 16 requires three references covering at least the last seven years.

Can I start the reactivation myself?

No. You have no DISS account. Only a Security Management Office, your new employer’s FSO or security team, can take the owning relationship and file the CSR, and the company must hold a facility clearance first under 32 CFR 117.9.

Does a clearance from another agency transfer over?

Through a Request Reciprocity CSR rather than a Recertify. SEAD 7 makes reciprocity mandatory for a determination at the same or higher level, subject to exceptions, including that an agency may decline an investigation more than seven years old. The FSO still needs the owning relationship first and checks Scattered Castles, OPM’s Central Verification System, and DISS.

DISS is the system of record today, though its functions are being folded into the National Background Investigation Services, with the government targeting a full cutover and legacy-system sunset by the end of FY2028. Whichever system holds your file, the trigger will not change, and it is not something you can file. Your one move is upstream of the paperwork: land a role with an employer that holds a facility clearance and an FSO ready to take the owning relationship. The Recertify CSR is three business days of their work. Getting to the point where someone will file it is the job.

Author

  • Ashley Jones is ClearedJobs.Net's blog Editor and a cleared job search expert, dedicated to helping security-cleared job seekers and employers navigate job search and recruitment challenges. With in-depth experience assisting cleared job seekers and transitioning military personnel at in-person and virtual Cleared Job Fairs and military base hiring events, Ashley has a deep understanding of the unique needs of the cleared community. She is also the Editor of ClearedJobs.Net's job search podcast, Security Cleared Jobs: Who's Hiring & How.

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  • Ashley Jones is ClearedJobs.Net's blog Editor and a cleared job search expert, dedicated to helping security-cleared job seekers and employers navigate job search and recruitment challenges. With in-depth experience assisting cleared job seekers and transitioning military personnel at in-person and virtual Cleared Job Fairs and military base hiring events, Ashley has a deep understanding of the unique needs of the cleared community. She is also the Editor of ClearedJobs.Net's job search podcast, Security Cleared Jobs: Who's Hiring & How.

    View all posts
This entry was posted on Thursday, July 16, 2026 2:44 pm