‘Continuous vetting’ procedures will soon apply to more feds governmentwide

By the end of fiscal 2024, all federal employees in “non-sensitive public trust positions” will be subject to more regular background checks.

In an effort to expand new personnel vetting procedures well beyond national security positions, agencies will soon have to begin implementing “continuous vetting” requirements for a larger subset of the federal workforce.

The Office of Personnel Management is now directing agencies to ramp up preparations to start continuous vetting (CV) procedures for employees in “non-sensitive public trust positions,” beginning in fiscal 2024.

OPM defines this section of the workforce as positions in both high and moderate risk levels. These include jobs involving, for instance, policymaking, public safety and health, law enforcement, fiduciary responsibilities or “other duties demanding a significant degree of public trust,” OPM said.

“At this time, federal agencies should begin considering how they will operationalize CV for this population, which would include, but is not limited to, tracking the population for enrollment, managing enrollment requirements and managing CV alerts,” OPM said in guidance to employees, published Tuesday.

The continuous vetting program will extend not only to federal employees in the competitive service, but also to those in the excepted service, employees at federal contractors and Defense Department non-appropriated fund (NAF) employees.

The continuous vetting process subjects certain federal employees to background checks at any given time. To carry out these procedures, agencies use automated record checks of employees’ credit history, criminal records and other information, and flag any instances where an employee faces an issue that may put their employment at risk, such as an arrest.

The continuous vetting system already exists for national security agencies that have employees with security clearances and access to classified information.

But more recently, the Biden administration has taken steps to try to modernize and expand governmentwide vetting processes for federal employees, through the “Trusted Workforce 2.0,” an initiative first launched during the Trump administration.

As part of the years-long effort, OPM proposed earlier this year to take continuous vetting procedures beyond national security agencies and extend to federal employees more broadly.

The upcoming expansion of the program follows after a pilot program that the Defense Counterintelligence and Security Agency (DCSA) began in June. The agency enrolled a smaller group of individuals in non-sensitive public trust positions into the continuous vetting program over the summer.

The goal of DCSA’s pilot, which is still ongoing, is to consider lessons learned before agencies begin broader enrollment for affected employees into continuous vetting procedures, set to start later this fiscal year.

The pilot is “a significant first step on the path for agencies to begin enrolling their non-sensitive public trust populations into continuous vetting,” the Security, Suitability and Credentialing Performance Accountability Council (PAC) said in a July 2023 update.

“The results of this pilot will inform the path forward for full implementation of the non-sensitive public trust population,” PAC added.

With the continuous vetting process soon taking effect for these employees, OPM also plans to eliminate requirements for the employees to undergo more dispersed background investigations, commonly called “reinvestigations,” which occur every five years for many non-national security positions in government.

For the time being, OPM said agencies should notify affected employees, including by initiating any required communications with federal unions.

Once implemented more broadly, OPM said it expects continuous vetting to have several benefits for agencies. The shift, according to OPM, can ease the burden on agencies when an employee moves to a new position, transfers to a different organization or returns to the federal workforce after temporarily exiting. In some cases, OPM said continuous vetting can also help detect potential personnel issues early on and support employees.

Agencies should aim to enroll all non-sensitive public trust employees into the continuous vetting program by the end of fiscal 2024.

Separately, OPM said it’s still in the process of finalizing regulations for continuous vetting procedures for “low-risk” federal employees. OPM said it expects these vetting checks to be “minimal” by comparison.

Eventually, OPM’s personnel vetting changes intend to cover all positions in the competitive service, the excepted service and the career Senior Executive Service, as well as federal contractor employees and NAF employees.

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