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Date: September 25, 1997
FIN 97-02, dated July 29, 1997, outlined OPM's implementation of new investigative standards as a result of Executive Order 12968. The purpose of this FIN is to give you guidance in completing the Standard Form 86 for submission to OPM and clarify the new investigative requirements.
As discussed in FIN 97-02, OPM has developed three new products, and adjusted the Single Scope Background Investigation (SSBI), to meet the new investigative requirements mandated by E.O. 12968. The National Agency Check with Law and Credit (NACLC), Access NACI (ANACI), SSBI-Periodic Reinvestigation (SSBI-PR) and the adjusted SSBI will be available October 1, 1997. The chart below illustrates the Case Type/Service, Sensitivity Level, and Access Codes to request these new products.
A, B, D
2, 3, 4
0, 1, 2, 3, 4, 5, 7, 8
0, 1, 2, 7, 8
3, 4, 5
A, B, C, D
If you want to use the SSBI for access other than TS, SCI, or Q, that investigation will not include the investigative factors mandated by E.O. 12968 that are unique to the TS, SCI or Q levels (i.e., spouse/ cohabitant NACS).
When suitability screening requirements support a more extensive level of investigation, you may request more than the minimum required investigation for access. For example, an MBI, LBI, BI, or SSBI may be used instead of the NACLC or ANACI.
Effective October 1, 1997, any initial or reinvestigation requesting Confidential/Secret/L Access with less than a NACLC or ANACI will be converted to the appropriate case type. Similarly, any PRIS (case type 13) for Top Secret, SCI, or Q Access will be converted to the new SSBI-PR (case type 18). For those investigative agencies that request the NAC portion from OPM and conduct the remaining portion themselves, the NAC (case type 06) will still be available. Please note that the NAC (06) will not include a credit search (unless extra coverage code 2 is indicated) or law checks.
Please be assured that all other OPM products currently in use will continue to be available. There will be no change to your SF85 and/or SF85P submissions, unless you have an agreement that is inconsistent with the new standards.
On all initial investigations, the employing agency is now responsible for corroborating the subjects date and place of birth through a check of appropriate documentation. For example, the subject may present a birth certificate to the employing agency. A check of the Bureau of Vital Statistics records should be conducted when any discrepancy is found to exist.
If you would like OPM to resolve discrepancies, or if your agency is not in a position to conduct the birth corroboration, OPM will continue to provide this service. We obtain birth corroboration through a Bureau of Vital Statistics (BVS) search in the state of the subjects birth. An agency may request a BVS search by placing an "L" in Block B on the SF86. A $15 surcharge will be applied to NACLC and ANACI products.
Note: BVS searches will not be automatically scheduled on the SSBI, SSBI-PR, or PRIS, as was done in the past. The requesting agency now must request a BVS search if needed.
The Personnel Security Committee of the Security Policy Board is currently tasked with revising the SF86 to meet the new guidelines and standards established by E.O. 12968. The current SF 86, revised September 1995, will continue to be used when submitting requests for access investigations. Some questions on the current form specify a time frame of seven years, which is not consistent with E.O. 12968. An attachment to this FIN provides interim instructions for questions on the current SF86. The attachment may be reproduced locally and a copy provided to each person asked to complete an SF86 for a Single Scope Background Investigation.
Any subject completing the SF86 for the NACLC or ANACI product must answer all questions within the time frames provided on the form. Those subjects completing the form for an SSBI-PR must provide information back to the completion date of the last investigation with a minimum requirement of five years.
OPM will continue to advise agencies of any further developments. If you have any questions please contact your Security Appraisal Officer at 202-606-1042 or the Program Services Office at 724-794-5612.
Richard A. Ferris Associate Director for Investigations
Inquiries: OPM-IS, Oversight and Technical Assistance Division, 202-606-1042
Code: 736, Investigations
Notice Expires Until Superseded