Why mental health issues don’t have to get in the way of security clearance
Mental health care is not an automatic disqualifier for national security clearances, and the way the Intelligence Community evaluates answers to mental health ...
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Among the roughly 160 pages of the SF 86 form are questions about your mental health. Now that form which anyone with national security clearance has had to deal with, that doesn’t decide whether you get the clearance, people do. And how they evaluate answers to mental health questions, though, that might be undergoing some revision. The Federal Drive with Tom Temin got more details from the Assistant Director of the Special Security Directorate of the National Counter Intelligence and Security Center, Mark Frownfelter.
Interview transcript:
Tom Temin: Mr. Frownfelter, good to have you on.
Mark Frownfelter: Hey, thank you for having me today, Tom.
Tom Temin: And I guess my first question is, what is the problem that we’re trying to correct here? Because the statistics show very few people of the thousands of applications every year actually do get rejected for mental health reasons.
Mark Frownfelter: Yeah, that’s correct. And there are many areas that investigators cover and adjudicators reviewed to determine individuals conduct, reliability, judgment and integrity. And psychological conditions is actually reflected in Guideline I as an adjudicator standard within what we call a SEAD, the security executive agent directive 4. But relevant mental health information, as you referenced, is just one piece of the whole person concept which is employed when rendering a final adjudicated decision allowing someone access to classified information. But for many agencies, the current SF 86 form is the sole source of information that investigators and adjudicators have regarding mental health conditions and the whole person concept within the adjudicated process does enable security professionals to make decisions about eligibility for access to classified information. Now, having said that, as a whole person concept is considered, seeking assistance from a mental health provider, whether through an organization’s Employee Assistance Program, or private practice does not jeopardize an individual’s security clearance and in fact, is seen as a sign of strength. And this is something you’ll hear me reiterate throughout this discussion. And that’s what we’re trying to correct. The perception, and this perceived stigma going into what is actually sought as information being collected. But seeking treatment is not a reason to deny or revoke a clearance, seeking treatment is a sign of good judgment. And it is viewed in a positive light that an individual recognizes that a problem exists and is willing to take positive steps toward resolving it. And seeking help frequently enables an individual to address a challenging problem and make positive gains in their life. But early intervention is a key component to successful and often lasting resolution to the vast majority of personal problems and mental health concerns, And we actually encourage people to seek counseling and or treatment so that those challenges do not rise to the levels that would adversely affect a person’s stability, judgment or reliability.
Tom Temin: So are the changes you’re considering to the form in some manner? Or is it simply a matter of training the adjudicators to make sure that they’re in line with that type of thinking?
Mark Frownfelter: A little bit of both. We’re working this effort, which you’ll probably hear about more in this discussion on Trusted Workforce 2.0 initiative for clearence reform efforts. Now under that we are looking to get a facelift for the SF 86. And based on input from a Question 21 working group comprised of [Intelligence Community] and DoD clinical and research psychologists with subject matter expertise and personnel security, we are going to recommend shifting Question 21 away from the relevant risk diagnosis and mental health treatment, and focus on an individual’s ability to function as well as behaviors and conduct that may rise to the level of a security concern. These recommended changes I think, will increase the efficacy of the psychological and emotional health screening questions. And our goal is to align Question 21 behaviors with the behaviors of concern listed and SEAD 4 Guideline I and enable security professionals to gather more accurate and reliable information from applicants about risk factors that may relate to mental and emotional well being, without asking the applicants to devote mental health diagnosis and treatment. And with this goes along with a look at the national training standards to make sure adjudicators and investigators are working to collect and review the information that we’re seeking.
Tom Temin: And I don’t want to make light of this, but I will make an absurd example. Suppose someone had a condition where voices were telling them that they had to divulge secrets to China or something. So that’s a mental health condition that is associated with, I don’t know, maybe schizophrenia and so on. Would there be a way of discerning that level of danger versus just what most people just have anxiety or even a touch of depression, which can be clinically, as you say, treated with good results?
Mark Frownfelter: Absolutely. And I think you hit the nail on the head there. There are conditions that would prevent someone based on their reliability and lack of judgment to have access to classified information. So applicants receiving treatment or counseling for the most common mental health issues such as depression and anxiety, as well as those seeking treatment or counseling after stressful events that that’s not an area security practitioners are concerned with. This would include anything from PTSD-related issues and experience, trauma in one’s life, grief counseling or marital counseling. But regardless of the diagnosis, the most effective treatment for any diagnosable mental condition is often a combination of medication and therapy. And taking medication for a mental health condition when it’s in compliance with a doctor’s instruction is no more of a concern in regard to one’s clearance and career than taking medication as prescribed for physical conditions such as an antibiotic treating an infection as an example. So I just want to make it clear that we’re not looking to penalize anyone for following a prescribed medication treatment plan. However, with the caveat with the introduction of medicinal marijuana purposes, that is still prohibited under federal law, but anything else that is not a concern of a security practitioner. I do want to point out that according to a study from 2022 by Mental Health America, more than half of U.S. adults with some sort of mental condition, and that equates to approximately 27 million individuals, do not seek or receive treatment or counseling and untreated mental illness can cause significant disruptions in individuals thinking, feeling, mood or ability to relate to others. And as a result could impair judgment, reliability, and trustworthiness. So obviously, we encourage people to seek assistance when they need to. But to your point, a mental health condition is only a security clearance concern when in the opinion of a competent medical authority, it may cause significant defect in the reliability, sound judgment or trustworthiness of the employee.
Tom Temin: And with respect to certain substances, it would seem like you have to just wait for, say congressional action on the CBD and the marijuana-type of derived medicines that people sometimes take. And then there’s even research going on in the use of psychedelics, which are not legal at all anywhere, but VA is testing them with people under DEA supervision and so forth an interagency effort, but the law would have to catch up to practice in that case. Fair to say?
Mark Frownfelter: That’s fair to say. And I just want to reiterate that federal law dictates policy in this area. We are aware of the changing landscape among states and local levels. And we’re looking to monitor that and address accordingly. But federal law is the deciding factor on policy in that area. So unless the law changes, that’s going to continue to be the stance throughout the federal government workplace.
Tom Temin: And in the age of continuous vetting, which the whole clearance process has moved toward or is mostly moved there. Therefore, you can track someone’s financial conditions or marital status, that can all give clues to possible vulnerabilities with respect to security. Is it possible to ethically track mental health and changes there? Or does HIPAA say not apply in the case of security clearance?
Mark Frownfelter: Yeah, continuous vetting. I’m glad you brought that up. That’s a major linchpin in our trusted workforce 2.0 effort. And, we’re looking to modernize the personnel vetting process for the first time in 60 years moving away from a traditional periodic reinvestigation model and enrolling individuals in a continuous vetting capability. What this does is allows us to identify issues in real time and offer workforce assistance much sooner. So we do look to identify issues up front such as financial issues, maybe substance abuse, addictive behaviors, and what this does, it allows individuals to seek out available resources much sooner. But early intervention is a key component for maintaining the well being of the workforce. But I do want to emphasize that an employee’s mental health is not tracked by security. Even though we’re going into this continuous vetting capability, mental health concerns only rise to the attention of security clearance professionals when an individual’s mental health condition significantly impairs their judgment, reliability, and trustworthiness. But what this continuous vetting does, it allows us to look to employees to leverage the robust resources that are offered by the federal government, obtain assistance when needed, and remain a very valuable and productive member of the workforce.
Tom Temin: And getting back to the issue of updating and realigning the questions and grouping them differently, as well as making sure that the people doing the evaluations are up to speed here. Is there a timeline on that? Do you have a program for that this might be completed?
Mark Frownfelter: Yeah, it’s an iterative process. We are obviously working to build out policy framework that continuous vetting right now is in place, and that’s alive and well. The departments and agencies right now we have approximately 4.25 million people in some sort of continuous vetting capability. So we’re getting information in real time. We’re looking at the forms right now. The SF 86 will get a facelift but that has to go through a series of reviews made available for public comment, and we’re working very closely with our partners to include the other Intelligence Community professionals, DoD, our industrial partners are involved and also, we hear from the Hill and legislative committee staffers who have ideas on that process as well. So all that taken into account, we are looking to give a facelift to the form and continue our work and the Trusted Workforce 2.0 effort, but that will obviously continue on into next year and possibly years to come.
Tom Temin: Mark Frownfelter is assistant director of the Special Security Directorate of the National Counterintelligence and Security Center. Thanks so much for joining me.
Mark Frownfelter: Hey, thank you very much, Tom.
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Tom Temin
Tom Temin is host of the Federal Drive and has been providing insight on federal technology and management issues for more than 30 years.
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