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Attachment to FIN 03-03

Security Professionals' Seminar - 2002

Q & A from SPS-2002 Workshops

Workshop A:Understanding Agency Checks

Q: Is there a cut-off date when waiting for pending NAC items to be resolved?How long should an agency wait for an OPM case to be closed complete?

A: OPM's current process is to close cases as soon as all Items under OPM control are complete.If there are incomplete Items OPM cannot control, we close the case CP (Closed-Pending).Federal Investigations Notice (FIN) 01-10, Risk Management When Adjudicating Initial Cases With Pending Items, attempted to provide guidance on making adjudication decisions in CP cases.In addition, an OPM representative should contact the requesting agency, when a case is pending over one year, to determine appropriate action.And, agencies may call our Federal Investigations Processing Center (FIPC) to follow-up on any pending case.OPM continues to try to streamline or improve the CP process.

Q: On the Case Closing Transmittal, what does an "ACCEPTABLE" result mean concerning Naturalized Citizens?

A: OPM inadvertently updated some Immigration and Naturalization Service (INS & SINS) Item results to Acceptable.The cases have been identified and steps are being taken to correct the results and reissue corrected Case Closing Transmittals.Any specific questions or requests to verify results should be directed to our CIS-Customer Service Team at FIPC.

Q: On the Citizenship Information System (CIS) screen operated by the INS, where can we find the codes used to show citizenship status, etc?

A: FIPC has access to most of the 119 tables of codes used by INS.If you would like a copy of any of them, contact John Levy via e-mail at jelevy@opm.gov

Several attendees requested a Point of Contact (POC) for INS's CIS. The INS presenter gave a POC of Dominique Gentile at 202-514-2989.

Q: A customer agency said that they are being told to go to the court to get information if an "A" is used in front of the INS citizenship number.What does this mean?

A: An "A" as part of the citizenship number indicates an individual has been a legal permanent resident for at least five years.Also, a person may use the "A" based on his or her parents' date of citizenship or other data about them.Usually, the person is 50 years old or older.An "A" does not always mean the person was an alien.Newer citizenship numbers start with "C" (for Certificate). You should contact INS with as much information about the person as possible, and they should search both their old and new systems ("A" and "C") in case the person used the wrong code.After becoming a naturalized citizen, a person no longer needs to use either letter.

Q: How does an agency get access to DCII?

A: The Defense Security Service website (www.dss.mil), under the button labeled "LOC, CVA, & DCII", has information on how a non-DoD agency can request access.

Q: Will customers be informed of all Debarment History?

A: When OPM receives a request for investigation, we search our records for information concerning any current or recent period of debarment.We notify the requesting agency, as appropriate, if the subject is currently under debarment or failed to admit a recent period of debarment.We will provide information concerning any prior periods of debarment to agency Security Offices if they specifically request this information.

WORKSHOP B - Understanding Credit Reports and Rap Sheets

Q: Concerning foreign addresses:What kind of credit information can OPM-CIS obtain?

A: Very little, if any, in any country outside the U.S. and its territories.We are pursuing methods to capture credit and other data for residents of Canada and Germany, but currently provide none in investigations unless addressed in personal testimonies or U.S. records.Part of the difficulty in obtaining such data from other countries is they do not use a standard, like our Social Security Number, to positively identify individuals.

Q: What do WEP and MOP mean in credit reports?

A: Wage Earner Plan and Manner of Payment.

Q: Will the type of court appear on a credit report?

A: No, unless it's obvious as part of the court's name.However, the disposition or a disposition code, showing the court's action, will be there.

Q: When a balance shows $0, does it mean the entire account has been paid off?

A: Not necessarily.There still could be a newer Past Due amount within a more recent reporting period that has yet to be reported.

Q: In Charged Off accounts, is money still owed?

A: Yes.Consumers frequently don't understand that, even when the creditor considers the debt Charged Off (as an uncollected loss), the consumer still owes them the money.

Q: If a person goes through several credit agencies or debt consolidation programs, would they all show up on the credit report?

A: Not necessarily.Not all deals, arrangements, or trade items, are reported.

Q: On FBI Rap Sheets, what is the purpose of an "NFF" program?

A: The purpose of the National Fingerprint File (NFF) program is to allow states to maintain control of their own records.

Q: What are the differences among:a Fingerprint Search, a National Crime Information Center (NCIC) Search, and an Internet Search?

A: Fingerprint Searches are based on fingerprints; NCIC Searches are based on name; and Internet Searches (background checks available on the Internet) are not associated with a search of the FBI databases and are based on name only.

WORKSHOP C - CIS Products and Services

Q: What is the status of OPM's case backlog and how long is it?

A: Refer to our FIN 02-09, Status of Background Investigations.We realize there are investigation requests that are critical to agencies and that require expedited handling, and to meet the need, OPM-CIS has established a Help Desk with Federal CIS staff to take requests for expedited service.However, please use this service only for genuinely critical requests.

Q: What are the new prices for the upcoming year?

A: OPM is pleased to announce that, based on a mid-year review, there will be no price increase for investigations services provided through the end of FY 2003.Although contracting costs have increased, we have been able to maintain FY 2002 prices due to OPM's ability to spread fixed costs over a significantly increased workload base.Agencies should plan for the standard, CPI-based price increase of approximately 3% beginning in FY 2004.In July, 2003 we will prepare and distribute pricing charts to be effective October 1, 2003.

Q: What forms can be used for what type investigations?

A: The investigative questionnaires, Standard Form (SF) 85, 85P and 86, are for the following purposes:

The SF 85 is completed by appointees to Non-Sensitive duties with the

Federal Government; it is used for NACI investigations;

The SF 85P is completed by persons seeking placement in positions currently designated "public trust", and for certain sensitive positions that do not require access to classified information; it is used for public trust investigations (NACI, MBI, LBI, BI, SBI & PRI); and

The SF 86 is completed by persons performing, or seeking to perform, national security duties for the Federal Government.This form is designed for use by all Federal agencies as the basis for ANACI, NACLC, SSBI, and SSBI-PR investigations used to determine access.The SF 86 may also be used for non-access positions that are considered Non-Critical-Sensitive, Critical-Sensitive, or Special-Sensitive under E.O. 10450 criteria, and can be used, when a position meets the criteria, for any investigation OPM conducts.

Q: Can we use the SF 85P instead of the SF 86 for an ANACI?For a NACLC?

A: Each form and OPM investigative product was designed to satisfy certain Federal or OPM standards, including those for access to classified information (see FIN 97-02).Contact your OPM-CIS Investigations Program Specialist if you need to use these forms for purposes other than those for which they were developed.

Q: Can OPM do anything about the confusing similarity in investigation acronyms (ANACI, NACLC, NACI) and confusion about the types of clearances they pertain to?

A: These products are very similar in the coverage they provide, but these are acronyms by which they have been known for years.We will attempt to be more aware of possible confusion and will define these acronyms more frequently in future discussions and publications.Whenever you want assistance with any of the specifics of OPM's products or about what investigation is required for what clearance, contact your Investigations Program Specialist at CIS in Washington, DC.

Q: Can we get the Advance Fingerprint data with an Advance NAC?

A: Yes, in cases requested on a SF 86.You must insert number "3" in the

Extra Coverage (block B) in the "Agency Use Only" section at the top of page one of the investigative questionnaire to generate an Advance NAC report from OPM.Then, you may insert letter "R" in the "Codes" block at the top of page one (above the "Agency Use Only" section) to generate an Advanced Fingerprint result.The Fingerprint report reflects the results of the search along with hardcopy of any arrest record that may exist; the Advanced NAC Report is a summary of results of all completed NAC Items, without hardcopy.They most likely will be generated at different timeframes, since the fingerprint is usually completed prior to the other NAC Searches.

Q: Will OPM retrieve the military medical records from the Department of Veterans Affairs (DVA) if they are not found at the Military Personnel Records Center (MPRC)?

A: OPM does not, as a matter of policy, obtain medical records from the DVA when they are not included in the MPRC file.However, on a case-by-case basis, OPM-CIS may obtain DVA medical records to resolve an issue involving drug, alcohol, or specific psychological counseling.

Q: What is a CIA "operations check"?Is it being done on our cases?Which types of cases?

A: CIA Operations checks on subjects (CIAO) and on spouses/cohabitants (SCIO) are inquires against the CIA's database of foreign nationals who are of interest to the intelligence community.This search would be appropriate, and should be included, in investigations when the subject, spouse, or cohabitant is a non-US citizen and the investigation is for clearance at the Top Secret or SCI level.We are currently changing our PIPS Scheduling to include this search.

Q: Which FIN explains when the OPM Minimum Background Investigation (MBI) was enhanced to meet Executive Order 12968 standards for Secret and Confidential Clearance?

A:The information is in FIN 01-03, dated December 22, 2000.It states that MBI's scheduled after January 1, 2001, meet the standards in EO 12968.

Q: Will e-Clearance/CVS accept the old MBI as a basis for the SECRET level?

A: OPM's Clearance Verification System will accept all OPM MBI's as a basis for Secret or Confidential clearance.

Q: What if a naturalized citizen has not registered with Selective Service by his 26th birthday?What does he have to do, or is he disqualified?If someone does not register, who is responsible for forwarding this information for investigation?Will the agency requesting an investigation from OPM receive a report?

A: An individual's failure to register with the Selective Service is considered a qualifications issue, and agencies should follow the guidance provided in

5 CFR 300.701-707 when considering such individuals for appointment.

[Direct questions to OPM's Examination and Qualifications Policy unit at 202-606-1298.]

Q: Where does an agency file a Certification of Investigation (CIN) if the applicant did not accept the position and no adjudicative decision was made?

A: If there is no Official Personnel Folder, there is no requirement to file the CIN. It is the agency's option whether or not to retain the CIN in an agency applicant or security file.

Q: Is the OFI-79A available electronically?

A: The form OFI-79A, used to report adjudication of OPM investigations, is generated by our automated system when each case is closed complete to the requesting agency, or when a copy of an OPM investigation file is sent to another agency.The form is not available electronically.However, the adjudication notification process will be added to our Personnel Investigations Processing System Agency Menu in the near future.

Q: Is it possible to modify the fingerprint-only SAC to include INS searches?How do we obtain more information about the availability and cost of various record checks?

A: The information needed to schedule an INS search is not included on the fingerprint chart or in the fingerprint transmission data file used to initiate fingerprint-only SAC's.We currently require an OFI Form 86C to collect required information for all except fingerprint-only SAC's.Contact your Investigations Program Specialist for details about the cost and timeliness of INS, or of any available record checks, and to establish a SAC agreement to implement any checks.

Q: Can a voicemail system be added to the Urgent BI hotline to leave messages if an agency cannot get through to it?

A: The Urgent BI hotline currently has a voicemail system.If the line is busy during normal business hours (7:00AM to 5:30PM ET) there will be a message indicating that your call will be answered as soon as possible.The message will be repeated one more time before the option to leave a message is given.If the call comes in after hours, the caller is immediately asked to leave a message and the call will be returned the next business day.

Q: Can OPM add a standard credit check to the NACI?

A: OPM conducts a large volume of NACI's for non-sensitive and low-risk public trust positions where credit searches are not necessary.Automatically including them would place a significant financial burden on the requestors ($10 per case).However, Credit can easily be added to a NACI by indicating Extra Coverage Code 2 in Block B of the SF 85.

Q: Can the PIPS Forms 11 and 12 (used to request changes to an SOI or SON) be placed on the CIS website in a fillable format so they can be sent electronically to OPM?

A: This will require programming support from our agency's IT department which we will attempt to obtain.

WORKSHOP D - Personnel Investigations Processing System (PIPS) Access and Clearance Verification System (CVS) for Agencies

Q: Does PIPS show "Discontinued" cases?

A:Yes, if using function #2, SII/DCII Search, PIPS will show a "DC" Closing Action (CA).If your office is a SOI (Security Office), you can call CIS-FIPC Telephone Liaison to determine a closing action on any case.The closing action is not displayed when using Function #1, Case Status.The case status on the Basic Case Data screen only shows Closed.

Q: Does OPM-CIS "perm cert" against the latest clearance?

A: A Security Office of one agency can only perm-cert against the appropriate level of active clearance that was granted by another agency, whether or not it is the latest clearance.

Q: How many perm-certs can we have?

A: You can renew a perm-cert each time it expires, as long as there is an active, revalidated clearance.

Q: How many SAC codes can PIPS handle at one time?

A: PIPS can hold up to 18 codes.Currently, agencies that are using Function 4 to submit their own SAC's are requesting codes A, B, C, D, E and X, on the on-line menu.PIPS identifies each character separately; when using multiple SAC Codes, no comma is needed to separate the characters.

Q: If you receive an electronic copy of an investigation via PIPS, do you continue to receive the paper copy in the mail as well?

A: No, the electronic copy replaces the mailed paper copy.However, if there are attachments which OPM does not have in an electronic format, then the entire case is mailed, and no electronic copy is generated.

Q: What happens if an agency has not logged on to PIPS for a while?

A: OPM monitors all PIPS use.The system automatically suspends ID's not used for 30 days, requiring the user to call OPM for a password reset.If an ID is not used for more than three months, OPM may follow-up with a check on user status at the agency, unless OPM is otherwise aware of specific staffing in an office.ID's inactive more than six months, after a user has previously been advised to activate the ID, may be removed from PIPS without further notice.Users should notify OPM if they no longer want to use PIPS.

Q: When phoning to request a file, why are agencies asked the purpose of the request but not asked this when requesting the file from PIPS?

A: When requests are made by phone, FIPC-Telephone Liaison must manually record the purpose of the disclosure.PIPS, however, automatically identifies the purpose based on the Menu function used to access data on the system.

Q: If an agency requested to receive cases electronically, would the agency ever be able to receive a case in another form?

A: If any case contains information that cannot be sent electronically (e.g., school transcripts, police reports, other attachments), then all the information is mailed.Once an electronic copy has been received by an agency, the file is no longer available to the agency in PIPS two weeks after it was downloaded.However, the agency may request a manual file release via a phone call to Telephone Liaison, and OPM will mail a copy.But, our file release policy is that we will not send another copy to an agency if it has been sent within the last 60 days, unless the agency indicates the file was not received.The agency should call Telephone Liaison and explain that the file was not received, and another copy of the file will be sent.PIPS also has an option to download closed case data to a computer, which allows the agency to use the data in its electronic form, but this currently requires the agency to supply its own PC for PIPS access.

Q: Is there a timeframe for investigative agencies to load all investigative information by mass load?

A: The option to allow agencies to transfer investigation records electronically to OPM, for both initial loads and ongoing updates of CVS, is currently in development.We will be in contact with the affected investigative agencies as soon as the process is available.

Q: To obtain PIPS access, is there a minimum activity requirement?

A: Currently, PIPS access is provided on request to any agency headquarters security office responsible for requesting and adjudicating OPM investigations. An agency should normally be checking on the status of their cases with, or requesting SII searches from, OPM about 25 times per week, or be receiving cases in the mail from OPM almost daily, to justify switching from telephone requests to PIPS access.Department of Defense security offices that just check the status of their OPM cases should request from DCII the OPM Case Status link that is already available in the DCII system.If there are any other PIPS access issues or uses you want to discuss, call your Investigations Program Specialist at OPM-CIS in Washington.In the future, when new technology is implemented to make PIPS access more readily available, OPM will notify security offices of expanded capabilities.

Q: In CVS, what does OPM do when an agency notifies OPM that it has suspended or revoked access?

A: OPM immediately notifies all other agencies that have a perm-cert on the clearance with the negative action.

Q: How is CVS tied to PIPS?

A: PIPS contains the records of people who have been investigated by the Federal Government (except the intelligence agencies), and the specific type of investigation (SSBI, NACLC, etc.) each person has had.CVS data, which is co-located with PIPS data, contains the records of National Security Clearances granted to individuals based on their investigations in PIPS.PIPS must contain a subject record and appropriate level of investigation before a clearance can be recorded.

Q: If an agency is given access to PIPS, is PIPS training provided?

A: Yes, if the office is in the Washington, DC metropolitan area.An Investigations Program Specialist and a computer technician will visit the agency, install and test the system, and provide on-site training.A User's Manual is provided.We ship a PC with written instructions for installation and a User's Manual to offices outside Washington, and we will guide them on system use by telephone.

Q: Can agencies get PIPS access to request CIRS reports?

A: Not at this time.OPM staff reviews all CIRS reports to ensure the information is accurate and provides what the agency needs.Investigations Program Specialists in our Customer Service Teams at FIPC or Washington can assist agencies and provide reports.

Q: Is there a required format for conducting a PIPS reconciliation?

A: Yes.Your Investigations Program Specialist can provide you with the required format.

Q: Using PIPS Send Message Function, can you send a question to a specific person (such as an Adjudicator)?

A: All PIPS messages go to OPM staff at FIPC, which then directs them to the appropriate office or person for action.You can ask in the message that it be forwarded to a specific person, or you may request assistance in a specific area, such as asking to be contacted by an Adjudicator. But if you know who you want to talk to, it would be faster to call.

Q: What if an agency does not have PIPS access and needs to suspend, revoke, or cancel a clearance?

A: The agency can contact OPM-CIS Telephone Liaison at 724-794-5228, and staff will enter the information into PIPS immediately.

Q: Do we have to notify OPM when making a second adjudication if we are using the original investigation (such as when an employee leaves but returns without a 2-year break in service)?

A: If you request a copy of the original investigation from OPM, a form 79A will accompany the file.If you act on an investigation you retained, you are not required to renotify OPM.However, if you obtain additional information which, when considered along with the OPM investigation, causes you to take an action different from the original one, you should notify OPM's Suitability Adjudications Branch at FIPC, which will determine what should be recorded in PIPS.

Q: Is it possible to place information regarding denials of clearances on CVS?

A: No, CVS is currently used only to record active clearances and subsequent actions on them.However, OPM will consider enabling this capability as it makes sense to share such information with others.

Q: For the SII Search in PIPS, are all identifiers really necessary?

A: Yes, we require them to comply with provisions of the Privacy Act.Without all identifiers, OPM cannot ensure that information being requested correctly matches the information we have.For example, if only the subject's name and SSN were entered into PIPS, there could be multiple records or false No Records due to individuals providing incorrect SSNs or names to OPM or to the requesting agency.Four identifiers ensure a much higher accuracy rate.

Q: In a PIPS SII-DCII search, when a non-investigative agency requests a file, why does PIPS ask, "Was the break 12 months or more?" when the regulations now state that an individual can have a break in service less than 24 months?

A: This process was designed in the 1980's when the standard was one year.However OPM is screening each request under the 24 month or more guidelines.We will update the program to ask about breaks of 24 months.In the interim, you may answer the question "NO" if the break was less than 24 months.And, if a file release request is improperly denied by FIPC, you may call or send a PIPS Message for assistance.

Q: Will DCII information ever be available through PIPS?

A: We continue to work with Defense Security Service to enable this link to DCII for our customers, but we are unable to accurately predict the date of successful implementation.

Q: How is Joint Personnel Adjudications System (JPAS) different from the Defense Clearance and Investigations Index (DCII)?What information is disclosed in each?

A: They are separate systems operated by different branches of the Defense Department.DCII, operated by Defense Security Service, is intended to record all investigations conducted by various Defense components, including criminal investigations by such organizations as Army CID, and any clearances granted by Defense units and military services.JPAS, operated by the Air Force, is expected to contain all clearances, granted to Defense employees and military personnel, based on any appropriate investigation conducted by any Federal agency.Until DoD settles differences between the systems and decides on centralization of records, OPM will continue to request and share information from both.

Q: When conducting an SII search and PIPS indicates there is a discrepancy, what happens?

A: PIPS generates a printed report at FIPC that shows both the data entered by the agency and the possible matches from PIPS.FIPC staff reviews the data and decides whether our data is the subject you want or it is a similar but not the same subject.FIPC also may follow-up with a request for additional information if they can't resolve identity with what they have.FIPC then responds by sending the requesting agency either a "NO RECORD FOUND" notice when they determine there is no match, or the requested information if there is a match.

Workshop E:Contractors and Suitability

Workshop F:Position Risk Level and Sensitivity Designation

Workshop G:electronic Questionnaires for Investigations Processing (e-QIP)

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