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    Background Investigations Position Designation Tool

     

    Overview

    Position Designation Automated Tool (PDT)

    Proper position designation is the foundation of an effective and consistent suitability and personnel security program. In order to ensure a systematic, dependable, and uniform way of making position designations, OPM provides the Position Designation Automated Tool (PDT) for those individuals within agencies charged with position designation responsibilities.

    Position Designation Automated Tool

    Agencies must abide by the standards established by OPM and the Office of the Director of National Intelligence (ODNI) for proper designation of covered positions. OPM, in coordination with ODNI, offers instruction and training to agencies in applying the Position Designation System.   Agencies must be able to demonstrate that they are adhering to the standards for proper designation of positions. Failure to comply may result in unfavorable audit findings under title 5 USC § 1104(b)(2) and 5 CFR 5.2, or withdrawal of delegated authority under 5 CFR 731.103(f).

    Position Designation System (PDS)

    The Position Designation System assesses the duties and responsibilities of a position to determine the degree of potential damage to the efficiency or integrity of the service from misconduct of an incumbent of a position. This establishes the risk level of that position. This assessment also determines if a position’s duties and responsibilities present the potential for position incumbents to bring about a material adverse effect on the national security, and the degree of that potential effect, which establishes the sensitivity level of a position. The results of this assessment determine what level of investigation should be conducted for a position.

    Before using the PDT, designators should first develop a thorough familiarity and understanding of the PDS. The success and consistency of the PDT are directly connected to the user's understanding of the various possible selections related to the national security and suitability (public trust) requirements, duties, and responsibilities available within the PDS. Without fully understanding the possible selections available, the users could inadvertently fail to make appropriate selections early in the PDT process, and this would impact the accuracy of the final position designation. A full understanding of the PDS and proper application of the PDT will ensure consistency.

    If you have questions concerning position designation, please contact Suitability Adjudications at (724) 794-5612, extension 7400. If you are interested in Position Designation training, please view the Agency Training portion of the FIS website.

    Federal Regulations

    Parts 1400 and 731 of Title 5, Code of Federal Regulations establish the requirements for agencies to evaluate relevant covered positions for a position sensitivity and position risk designation commensurate with the duties and responsibilities of those positions. Specifically, section 1400.101(d) states, “All positions must be evaluated for a position sensitivity designation commensurate with the responsibilities and assignments of the position as they relate to the impact on the national security, including but not limited to eligibility for access to classified information.” Section 731.106(a) of Title 5, Code of Federal Regulations states, "agency heads must designate every covered position within the agency at a high, moderate, or low risk level as determined by the position's potential for adverse impact to the efficiency or integrity of the service." Also, each part cross references the requirement for risk and sensitivity designations. See sections 1400.201(c) and (d), and section 731.106(c)(2).

    Automated Tool

    As required by section 1400.201(b) of title 5, Code of Federal Regulations (CFR), this system is for uniform and consistent position designation of:

    1. National security positions in the competitive service, the excepted service where the incumbent can be noncompetitively converted to the competitive service, and Senior Executive Service (SES) positions held by career appointees in the SES within the executive branch; 1
    2. All "covered positions" as defined in 5 CFR 731.1012
    3. Other excepted service positions within the executive branch and contractor positions, when authorized by agency policy and to the extent consistent with law, or when directed by the Security Executive Agent; and 3
    4. Any positions, including contractor employee positions, when the investigation will be conducted under the Federal Investigative Standards prescribed by the Office of Personnel Management and the Office of the Director of National Intelligence in December 2012. 4

    To determine the proper designation of a position and its required corresponding level of investigation, the position description and any other necessary supplemental information (e.g. human resources, management and security office input) must be carefully evaluated to assess the nature of the position as it relates to the potential material adverse impact to the national security, and -– if it is a covered position under part 731 -- its impact on the efficiency or integrity of the service.

    The following position designation system consists of a four-step process that will guide the designator through an examination of the position’s duties and responsibilities. The completion of this process will result in a final designation for the position which, in turn, will determine the investigative requirements for the position in question.

    It is important to keep in mind that for covered positions as defined in 5 CFR part 731, the designator must look at both national security and public trust duties and responsibilities. Some duties accounted for herein occur under both the national security and public trust sections of the process because of the duty’s potential impact on one concern and/or the other. For covered positions, a critical-sensitive or special-sensitive national security designation automatically confers high-risk public trust designation, and a noncritical-sensitive national security designation automatically confers a moderate-risk public trust designation unless, as described in the following sections of the position designation system, it requires a higher designation. See 5 CFR 1400.201(c), (d).

    1 5 CFR 1400.102(b)

    2 5 CFR 731.106(a)

    3 5 CFR 1400.102(b)

    4 Pursuant to an assignment of functions under section 2.2(e) of E.O. 13467, the December 2012 Federal Investigative Standards apply to investigations for contractor employee fitness.

    Glossary

    A | B | C | D | E | F | G | H | I | J | K | L | M | N | O | P | Q | R | S | T | U | V | W | X | Y | Z

    Agency
    An Executive agency, which is defined by 5 U.S.C. 105 as an Executive department, a Government corporation, and an independent establishment.
    Automatic High-Risk Conditions for Public Trust
    These conditions are duties that present the possibility of the gravest impact to the public’s trust, likely to produce inestimable damage. The degrees of potential impact are broadly defined. It is necessary to look at each public trust duty and evaluate the entire row of example duties provided to establish context to determine the scope of potential impact to the public’s trust. This reveals the potential damage to the integrity and efficiency of the service and the public’s trust.
    Close Technical Supervision

    Continuing review of all work by a technical expert, such as:

    1. The supervisor provides continuing or individual assignments by indicating generally what is to be done, limitations, quality and quantity expected, deadlines, and priority of assignments.
    2. The supervisor provides additional, specific instructions for new, difficult, or unusual assignments, including suggested work methods or advice on source material available. The employee uses initiative in carrying out recurring assignments independently without specific instructions, but refers deviations, problems, and unfamiliar situations not covered by instructions to the supervisor for decision or help. The supervisor assures that finished work and methods used are technically accurate and in compliance with instructions or established procedures. Review of the work increases with more difficult assignments if the employee has not previously performed similar assignments.
    3. For both one-of-a-kind and repetitive tasks, the supervisor makes specific assignments accompanied by clear, detailed, and specific instructions. The employee works as instructed and consults with the supervisor as needed on all matters not specifically covered in the original instructions or guidelines. For all positions the work is closely controlled. For some positions, the control is through the structured nature of the work; for others, it may be controlled by the circumstances in which it is performed. In some situations, the supervisor maintains control through review of the work. This may include checking progress or reviewing completed work for accuracy, adequacy, and adherence to instructions and established procedures.
    Critical-Sensitive Positions
    As defined in 5 CFR 1400.201(a)(2), critical-sensitive positions are, “national security positions which have the potential to cause exceptionally grave damage to the national security.” Also, in accordance with 5 CFR 1400.201(c) a critical-sensitive position automatically carries with it a risk designation under 5 CFR 731.106 at the high level.
    Critical and Extremely Important Items of War
    Those items vital to success in war, or without which success would be unlikely.
    Customer Service
    Customer care duties that support the delivery of an agency’s services. The scope of the word “customer” would be defined based upon the duties outlined in the position description. For example, one agency’s customers might be other Government agencies, but a different agency may primarily serve non-Government entities or the general public (e.g. the duties of employees with the General Services Administration vs. those of a Social Security Administration employee); however, that is not to suggest every employee of those agencies would be assumed to have customer service responsibilities; that is defined by the specific duties of the job.
    Damage to the National Security
    E.O. 13526 characterizes damage to the national security as “harm to the national defense or foreign relations of the United States from the unauthorized disclosure of information, to include sensitivity, value, and utility of that information.”
    Exceptionally Grave Damage to the National Security
    The capacity to cause extremely serious harm to the national security. Also, the minimum level of damage an incumbent’s neglect, action or inaction must have the potential to cause for a position to be designated as critical-sensitive.
    Inestimable Damage to the National Security
    The capacity to cause harm to the national security too severe to be computed or measured. Also, the minimum level of damage an incumbent’s neglect, action or inaction must have the potential to cause for a position to be designated as special-sensitive.
    Information Technology
    As defined in OMB Circular A-130, information technology is, "any equipment or interconnected system or subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information by an executive agency. For purposes of the preceding sentence, equipment is used by an executive agency if the equipment is used by the executive agency directly or is used by a contractor under a contract with the executive agency which (i) requires the use of such equipment, or (ii) requires the use, to a significant extent, of such equipment in the performance of a service or the furnishing of a product. The term "information technology" includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources. The term "information technology" does not include any equipment that is acquired by a Federal contractor incidental to a Federal contract. The term "information technology" does not include national security systems as defined in the Clinger-Cohen Act of 1996 (40 U.S.C. 1452)."
    Information System
    As defined in OMB Circular A-130 an information system is, "a discrete set of information resources organized for the collection, processing, maintenance, transmission, and dissemination of information, in accordance with defined procedures, whether automated or manual."
    Limited Impact to the Public's Trust
    Likely to produce some harm or discernible damage to the public’s trust. The degrees of potential impact are broadly defined. It is necessary to look at each public trust duty and evaluate the entire row of example duties provided to establish context to determine the scope of potential impact to the public’s trust. This reveals the potential damage to the integrity and efficiency of the service and the public’s trust.
    Limited or No Supervision

    Occasional review from a perspective of major policy issues by a superior who likely has no relevant expertise in the technical aspects of the duties performed.

    The supervisor provides administrative direction with assignments in terms of broadly defined missions or functions. The employee has responsibility for independently planning, designing, and carrying out programs, projects, studies, or other work. Results of the work are considered technically authoritative and are normally accepted without significant change. If the work should be reviewed, the review concerns such matters as fulfillment of program objectives, effect of advice and influence on the overall program, or the contribution to the advancement of technology. Recommendations for new projects and alteration of objectives usually are evaluated for such considerations as availability of funds and other resources, broad program goals, or national priorities.

    Moderate Impact to the Public's Trust
    Likely to produce a fair amount of harm or serious damage to the public’s trust. The degrees of potential impact are broadly defined. It is necessary to look at each public trust duty and evaluate the entire row of example duties provided to establish context to determine the scope of potential impact to the public’s trust. This reveals the potential damage to the integrity and efficiency of the service and the public’s trust.
    National Security
    As defined in 5 CFR 1400.102(a), national security "refers to those activities which are directly concerned with the foreign relations of the United States, or protection of the Nation from internal subversion, foreign aggression, or terrorism."
    Noncritical-Sensitive Positions
    As defined in 5 CFR 1400.201(a)(1) noncritical-sensitive positions are, “national security positions which have the potential to cause significant or serious damage to the national security”. Also, in accordance with 5 CFR 1400.201(d) a noncritical-sensitive position automatically initially carries with it a risk designation under 5 CFR 731.106 at the moderate level, unless the agency determines that the position should be designated at the high level. Agencies shall designate the position at the high level where warranted on the basis of criteria set forth in OPM issuances as described in 5 CFR 731.102(c).
    Periodic Review

    Ongoing spot review from a perspective of policy and organizational concerns by a superior with expertise in the technical aspects of the duties performed.

    The supervisor sets the overall objectives and resources available. The employee and supervisor, in consultation, develop deadlines, projects, and work to be done. The employee, having developed expertise in the line of work, is responsible for planning and carrying out the assignment, resolving most of the conflicts that arise, coordinating the work with others as necessary, and interpreting policy on own initiative in terms of established objectives. In some assignments, the employee also determines the approach to be taken and the methodology to be used. The employee keeps the supervisor informed of progress and potentially controversial matters. Completed work is reviewed only from an overall standpoint in terms of feasibility, compatibility with other work, or effectiveness in meeting requirements or expected results.

    OR

    The supervisor makes assignments by defining objectives, priorities, and deadlines and assists the employee with unusual situations that do not have clear precedents. The employee plans and carries out the successive steps and handles problems and deviations in the work assignments in accordance with instructions, policies, previous training, or accepted practices in the occupation. Completed work is usually evaluated for technical soundness, appropriateness, and conformity to policy and requirements. The methods used in arriving at the end results are not usually reviewed in detail.

    Severe Impact to the Public's Trust
    Likely to produce a substantial degree of harm or serious damage to the public’s trust. The degrees of potential impact are broadly defined. It is necessary to look at each public trust duty and evaluate the entire row of example duties provided to establish context to determine the scope of potential impact to the public’s trust. This reveals the potential damage to the integrity and efficiency of the service and the public’s trust.
    Significant or Serious Damage to the National Security
    The capacity to cause noteworthy harm to the national security. Also, the minimum level of damage an incumbent’s neglect, action or inaction must have the potential to cause for a position to be designated as noncritical-sensitive.
    Significant Personal Gain
    Noticeably or measurably benefiting an individual’s interests in a substantial way (e.g. a large monetary or other valuable personal benefit, benefit to one’s family or friends, etc.; providing a level of affluence or a lifestyle otherwise not justifiable).
    Special-Sensitive Positions
    As defined in 5 CFR 1400.201(a)(3) special-sensitive positions are, “national security positions which have the potential to cause inestimable damage to the national security.” Also, in accordance with 5 CFR 1400.201(c) a special-sensitive position automatically carries with it a risk designation under 5 CFR 731.106 at the high level.

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