State Department Duplicates Investigative Efforts

There are some things just make you shake your head and wonder why? In the background investigation world, quite often it is the Department of State (DoS) who are involved in things that don’t quite pass the common sense test. Let me give you an example of a scenario I ran across recently:

A contractor working for Company A has an active Secret clearance based on a Tier 5 investigation completed by DoD in 2019 (previously cleared at Top Secret for previous employer). Company A works on contracts for a variety of agencies, including DoD and DoS. It is DoS policy that all personnel working for them on this project must undergo a moderate risk public trust investigation (Tier 2).

Now, common sense would dictate a contractor who already has an active clearance based on a favorable Tier 5 background investigation already meets or exceeds the Tier 2 requirement, right? Wrong! For some unknown reason DoS insisted on completing their own Tier 2 investigation instead of accepting reciprocity for the completed DoD Tier 5 or just requesting a copy of it for their own review. Not only is this a waste of time and resources, but it is inconsistent with ODNI reciprocity guidance.

Does DoS actually think they will get more information from a Tier 2 than from a Tier 5 investigation? With continuous evaluation and vetting programs in place is there something that might pop up that would be disqualifying for a public trust position that would not affect a person’s clearance? Not likely! There are other agencies who also follow this lack of common sense; one that comes to mind is the National Institute of Health. It is befuddling why they are not following the same guidance for background investigations as the rest of the Federal Government.