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Date: June 17, 2002
On April 29, 2002, OMB issued Bulletin No. 02-03, "Expedited Processing of National Security Clearances using the Clearance Verification System." That Bulletin instructs each agency to "load" agency specific clearance information into the CVS. It also instructs agencies to automate their clearance information. The latter is because, although agencies must initially revalidate clearance information every 180 days, we anticipate requiring a much more frequent revalidation in the near future, making manual record handling cumbersome and costly.
Since Federal Investigations Notice (FIN) 01-06, which this notice supercedes, the e-Clearance Partnership initiative has modified the information to be loaded into the CVS. A few data elements have been added, and there are changes that affect how the system will be used. Some of the changes may include data elements that are not presently being captured in agency records. These data elements are relevant to clearance processing and records should be modified to capture all these elements. You will find a description of the file format necessary for your automated records to be loaded into the CVS, attached to this FIN. It also shows which data elements are required for a successful automated transaction, and which are optional.
The CVS is maintained on the Personnel Investigations Processing System (PIPS) and is available through a search of the Security/Suitability Investigations Index (SII). The SII records personnel investigations conducted by the OPM, and by other agencies who have delegated authority to conduct their own personnel investigations. We have designed the CVS to check the SII for an appropriate level investigation before loading a clearance record. The CVS will not allow a clearance to be entered unless it is associated with an appropriate level of investigation previously recorded in the SII. For example, an agency will be unable to record a TOP SECRET security clearance for an individual when the only record of an investigation in the SII is a NACI.
Before OPM can successfully load your clearance information into the CVS, your clearances must be accurate and up-to-date, and an adequate basis investigation recorded in the SII. The OPM automatically records investigations scheduled through OPM's Investigations Service, so if the OPM is your investigative service provider no additional effort is required. However, if your agency has delegated authority and you conduct your own investigations, you need to be certain the appropriate investigation has been reported to the OPM, and recorded in the SII, before attempting to load clearance data. If the appropriate investigation is not already in the SII, the clearance will not load for that individual.
Some investigative agencies report their scheduling of an investigation using an OFI-79. The OFI-79 only serves as notice that a certain type of investigation was scheduled not that it was ever completed. Although the CVS presently allows a clearance to be loaded if it is supported by an OFI-79, the e-Clearance Partnership has determined that this is not in the best interest of the community. We are now working with agencies that use the OFI-79 to have them load a trace record of their investigations and status so that the match of an active clearance may be made against a completed investigation. Interim clearances may be matched against scheduled investigations. We expect this change over to occur toward the end of this calendar year and we will notify you when it does.
Many agencies are now dealing with automated record systems and have successfully participated in this endeavor thus far. Once your agency's procedures are established, and if you choose to submit a batch file for processing, we will return a listing showing successful transactions along with an error report for any attempted clearance loads that are not supported by the appropriate investigation, and or discrepant subject identifiers. Reconciling these errors can be much more time consuming than the automating and loading so, ensuring the accuracy of your data before loading minimizes the time spent reconciling errors.
We have built in checks to ensure that clearance information posted on the CVS is reliable. One of these checks is the periodic re-validation required for each clearance. However, each granting authority is responsible for the accuracy of each record and that the eligibility was properly determined. Remember: others will be relying on your information in the CVS to make decisions about access to classified national security information.
Agencies are required to execute a memorandum of understanding with the OPM before submitting live data to the CVS. This agreement will outline the responsibilities of both parties. OPM analysts are available to assist you in determining the best way for you to participate in this effort.
As a reminder, the OMB Bulletin requires agencies to notify the e-Clearance Project Manager of the agency contact for this initiative. It also requires notification to both the Project Manager and OMB when your agency has completed this loading clearance information into the CVS. This FIN does not change those requirements. The OMB contact for CVS has changed since the issuance of the OMB Bulletin. The contact now is Steve Galvan who can be reached at Stephen_D._Galvan@omb.eop.gov.
When your agency is ready to begin loading your data or wants to start the process, please contact your OPM-IS Appraisal and Assistance Officer at 202-606-1042. If you have questions about the OMB Bulletin, contact the e-Clearance Project Manager, John Crandell, at 202-606-2084 or JHCrande@opm.gov. If you need technical guidance in establishing a database, contact your agency's information technology office. If you have technical questions related to preparing the automated transaction file, contact Roy Parkinson at 202-418-3228 or CTCRRNP@opm.gov.
Kathy Dillaman, Acting Associate Directorfor Investigations
Inquiries: OPM-IS, Oversight and Technical Assistance Division, (202)-606-1042
Code: 736, Investigations 732, National Security Positions
Distribution: Non-DoD SOIs
Letter expires: Upon Notice