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Department of the Interior
Departmental Manual
Effective Date: 1/8/10
Series: Law Enforcement and Security
Part 441: Personnel Security and Suitability Program
Chapter 4: Investigation Requirements
Originating Office: Office of Law Enforcement and Security
441 DM 4
4.1 Basic Requirements. Background investigations, reinvestigation descriptions and scope
specifications for each of type of investigation are contained in Section 4.15 and Illustration 1 of
this chapter. The minimum required investigation relative to each sensitivity or risk level
designations are contained in Illustration 2 of this chapter. The investigation requirements
(Bureaus/Offices, at their discretion, may exceed the required investigation/reinvestigation level)
are also applicable to contractor employees. If a previously completed investigation meets the
scope and standards of the required investigation and the individual does not have a break in
Federal service (continuous employee or contractor staff service to a Federal agency) of more
than 24 months, an investigation is not required. Individuals who had any break in service and
during such break were associated with a foreign government or foreign organization must have
a new investigation. For Sensitive positions, Standard Form 86C (Certification) or an updated
Standard Form (SF) 86, Questionnaire for National Security Positions, must be reviewed along
with other applicable records. A reinvestigation is not required unless derogatory information is
identified which indicates the person may no longer satisfy the standards of Executive Order
(EO) 12968, Access to Classified Information.
4.2 Timing of Investigations. Investigations for post-placement employment into Non-
Sensitive/Low Risk positions, Non-Critical-Sensitive and Moderate and High Risk positions, and
if a waiver is authorized, Critical-Sensitive, shall be initiated by the appropriate Bureau/Office
Human Resources/Personnel or Security Office within 14 working days of placement (Entry on
Duty – EOD). For Special-Sensitive and Critical-Sensitive positions if a waiver is not
authorized, investigations must be conducted pre-placement. The waiver process is not allowed
for Special Sensitive positions.
4.3 Reciprocity. A re-investigation is not required when a closed, complete and favorably
adjudicated investigation by a Federal investigative agency/office meets the scope and standards
for the sensitivity or risk level of the position or contract and the individual has not been
separated from Federal service or contractor staff service to a Federal agency for more than 24
months. However, the individual must complete an OF-306, Declaration for Federal
Employment. The individuals most recent SF 85, 85P, 86, etc., must also be obtained by the
Bureau/Office Security Officer or Human Resources/Personnel Specialist to assist in the
reciprocity verification process. If the most recent SF 85, 85P, 86, etc., is not available, the
individual must complete a new SF 85, 85P, 86, etc.
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If suitability issues are admitted on the OF-306 or the investigative questionnaire, or if they are
otherwise developed, the issues must be investigated and adjudicated. If there are no suitability
issues, and the break in service does not exceed 24 months, a new investigation is not necessary.
Investigations shall not be duplicated when the investigation meets the minimum scope and
standards for the sensitivity or risk level of the position. Previously conducted investigations and
personnel security/suitability determinations by Federal government agencies shall be mutually
and reciprocally accepted. The servicing Human Resources/Personnel Office shall ensure the
appropriate security/suitability data is reflected on the SF 75 (Request for Preliminary
Employment Data) and/or by checking the OPM Security/Suitability Investigation Index (SII).
Additionally, the Bureau/Office Security Office should contact the selectee’s current security
office to obtain any relevant security/suitability information. Bureau/Office security personnel
shall not request the prior investigative files for review unless:
A. Significant derogatory security/suitability information is received from the Human
Resources/Personnel Office or the selectee’s Security Office.
B. Potentially disqualifying information has developed since the last favorable
adjudication.
C. The security clearance eligibility has been officially withdrawn, denied, or revoked
for cause.
4.4 Waiver of Pre-appointment Investigative Requirement. A waiver of the pre-
appointment investigative requirement may be authorized in “case of emergency” provided that
such action is necessary in the interest of national security or the efficiency of the Federal
service. The servicing Human Resources/Personnel Office shall ensure the following checks are
conducted and the pertinent documentation (Section 4.4B, C, and D of this chapter) is submitted
through their respective Bureau/Office Security Officer or designee to the head of the
bureau/office:
A. Review of the person’s investigation form;
B. DI 1912, Request for Waiver of Pre-appointment Investigative Requirement for a
Critical-Sensitive Position (Illustration 3 of this chapter);
C. DI 1990, Pre-appointment Background Check (Illustration 4 of this chapter); and
D. Justification for the waiver.
Note: Granting a waiver does not provide authorization for access to classified national security
information or delegation of law enforcement authority. Request for approval of all
commissioned law enforcement waivers must be processed through the Office of Law
Enforcement and Security (OLES) and approved by the Director. Waivers are optional for
positions designated Non-Critical-Sensitive, High Risk or Moderate Risk.
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4.5 Critical-Sensitive Positions. A waiver can be requested when appointing an individual to
a Critical-Sensitive position prior to completion of the required background investigation. An
advance National Agency Check (NAC) shall be requested as part of the 35-day service
background investigation.
4.6 Special-Sensitive Positions. The pre-appointment investigative requirement will not be
waived for positions designated Special-Sensitive.
4.7 National Security Duties Performed by Contractors. All non-Federal employees
needing security clearances must be processed through the National Industrial Security Program
per DM Part 443.
4.8 Contractor/Consultant Positions and Other Classifications of Individuals. The
investigative requirements stipulated in this Part apply equally to all contractors, subcontractors,
and consultants performing under a contract and/or consultant agreement to perform activities of
the Department, as well as other classes of individuals. Existing contractors/consultants who
were not subject to a pre-appointment investigation must subsequently meet the investigation
requirements in a timely manner. Prior to initiating the investigation, the Bureau/Office Security
Office will review the investigation forms for any potential suitability issues. If the forms
contain disqualifying information, the Bureau/Office Security Officer may find the individual
unsuitable for access to sensitive systems and/or data. In such cases an investigation will not be
requested and the individual will not be allowed access to the sensitive systems and/or data.
Each individual must be a U.S. Citizen or a non-U.S. Citizen who meets the requirements of the
Federal appropriations ban, immigration rules, and executive order restrictions on appointing
non-citizens in the competitive service. For purposes of conducting required background
investigations, non-U.S. Citizens must have continuously resided in the United States for the last
three years. Contracting Officers will ensure that the contracts include the investigation and
citizenship requirements. Individuals will use the same forms required for Federal service
employees unless otherwise instructed by the investigative agency. Effective October 1, 2007,
all Federal departments and agencies must ensure that their new contractor hires have been
verified through the Employment Eligibility Verification Program (E-Verify). This program
complements existing implementation plans in support of Homeland Security Presidential
Directive 12 (HSPD-12). The program allows employers to verify name, date of birth, and social
security number, along with immigration information for non-citizens, against Federal databases
in order to verify the employment eligibility of both citizen and non-citizen new hires.
Note: Additional policy regarding non-U.S. Citizens is in the process of being drafted by the
Office of Personnel Management (OPM) (as a result of HSPD-12) and will supersede the
aforementioned guidelines.
4.9 Initiating Investigations. OPM’s Federal Investigative Services Division, through
Federal and/or contracting staff, conducts all investigations for DOI. Before requesting an
investigation through OPM, the bureau/office submitting office shall review all documents used
to initiate the investigation to ensure that all items are properly completed. Errors/omissions in
completing the forms will cause delays in the processing of the investigation.
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4.10 Investigation Forms. The SF 86, Questionnaire for National Security Positions, is the
appropriate form to request investigations for all positions designated Special-Sensitive, Critical-
Sensitive, and Non-Critical-Sensitive. The SF 85P, Questionnaire for Public Trust Positions, is
used for positions designated High and Moderate Risk. The SF 85, Questionnaire for Non-
Sensitive Positions, is used for all Non-Sensitive/Low Risk positions. The SF 87, fingerprint
card, is used for all Federal employees and the FD 258 is required for contractor employees.
4.11 Exceptions to Investigative Requirements for Non-Sensitive Positions.
A. Certain Non-Sensitive positions are exempt from the investigative requirements,
provided that the employing bureau/office conducts such checks as it deems appropriate to
ensure that the employment or retention of such a person is clearly consistent with the interest of
the Federal service. Regardless of the type of appointment, 446 DM 2, Personnel Qualifications
and Standards, requires all permanent and temporary/seasonal law enforcement positions, as
defined in 446 DM 1.3E, be designated, at a minimum, Critical-Sensitive. The above positions
are not exempt from the investigative requirements. Positions that may be exempt are:
(1) Intermittent, Seasonal, Per Diem, or Temporary, not to exceed an aggregate of
180 days in either a single continuous appointment or series of appointments; or
(2) Aliens employed outside the United States.
B. Requests for exemptions from the investigative requirements for positions in other
circumstances shall be forwarded to OLES for appropriate action.
4.12 Background Investigations and Periodic-Reinvestigations. Bureaus/Offices may, at
their discretion, have a higher level background investigation or reinvestigation conducted than
is specified as a minimum required level within this chapter. The incumbent of a position
designated either Special-Sensitive or Critical-Sensitive with access to Top Secret classified
information is subject to a reinvestigation 5 years after placement and once each succeeding 5
years. Positions designated Critical-Sensitive and Non-Critical-Sensitive with access to Secret
and/or Confidential classified information require a reinvestigation every 10 years. Positions
designated High, Moderate and Low Risk/Non-Sensitive do not require a reinvestigation;
however, each bureau/office may place a reinvestigation requirement for its employees.
Reinvestigation requirements for law enforcement positions are specified in 446 DM 2.
4.13 Movement from Public Trust Positions to National Security Positions. Individuals
moving from Public Trust positions to National Security positions must complete the SF 86 prior
to placement. If the individual has received the required investigation for the Public Trust
position, that investigation must be upgraded or updated to meet the standard for the National
Security position.
4.14 Adjudication. The Bureau/Office Security Officer is responsible for ensuring the
adjudication of both National Security and Public Trust positions for all employees and, as
appropriate, other positions for contractors and other classes of employees (i.e., volunteers, guest
researcher, interns, etc.). Bureau/Office Security Officers and all designees who adjudicate (i.e.,
441 DM 4
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Human Resource/Personnel Office staff) must be Federal employee(s) and have favorably
adjudicated background investigations at a level equal to or greater than the investigation that
they are adjudicating. See 441 DM 5 for more specific details.
4.15 Types of Investigations. The following are the most frequently requested investigations:
A. Access National Agency Check and Inquiries (ANACI). Minimum investigation
required for Secret or Confidential clearance under EO12968 or DOE “L” clearances. This
investigation is generally used for those positions designated as Low Risk requiring Secret
access and was developed to comply with EOs 10450 and 12968.
B. Background Investigation (BI). Generally used for High Risk Public Trust positions,
non-managerial commissioned law enforcement positions, or Non-Critical Sensitive positions
with a high risk point component that requires access to secret information.
C. Limited Background Investigation (LBI). Generally used for Moderate Risk Public
Trust positions with a high position risk point value, non-managerial commissioned law
enforcement temporary positions, or Non-Critical Sensitive positions with a moderate risk high
point component that require access to secret information.
D. Minimum Background Investigation (MBI). Generally used for Moderate Risk
Public Trust positions or Non-Critical Sensitive positions with a moderate risk low point
component that requires access to secret information.
E. National Agency Check (NAC). The NAC is part of every OPM background
investigation. It consists of searches of the Office of Personnel Management Security/Suitability
Investigations Index (SII), Defense Clearance and Investigations Index (DCII), the Federal
Bureau of Investigation (FBI) Identification Division and FBI Headquarters files.
F. National Agency Check and Inquiries (NACI). Minimum investigation required for
Non-Sensitive/Low Risk positions. All coverage is obtained through written inquiry and
computer linkages. A review of documents and records, including a NAC with written inquiries
to law enforcement agencies, former employers and supervisors, listed references, and schools is
performed.
G. National Agency Check with Local Agency Checks and Credit Check (NACLC).
Minimal investigation required by EO 12968 on contractors or consultants for access to Secret or
Confidential classified information. This is the reinvestigation for a secret clearance for Low
Risk Federal employees.
H. Single Scope Background Investigation (SSBI). The SSBI meets the coverage
requirements of EO 12968 for Top Secret, Sensitive Compartmented Information (SCI), and
DOE “Q” access. A personnel investigation that provides extensive information regarding an
individual that consists, if applicable, of a NAC, a spouse or cohabitant NAC, date and place of
birth corroboration, citizenship, education, agency checks, public records, and subject interview.
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I. Child Care National Agency Check and Inquiries (CNACI). Since June 1, 1997, OPM
Investigations Service has been offering an investigative product exclusively designed for child
care provider positions. The Child Care National Agency Check with Written Inquiries
(CNACI) was designed by a consortium of Federal agencies that offer child care services.
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Illustration 1
Types of Investigations
FPPS
CODE
TYPE OF
INVESTIGATION
SCOPE: EXPLANATION OF INQUIRY
1
NACI
CNACI
• Employment 5 years
• Education 5 years and highest degree verified
• Residence 3 years
• References (not mandatory)
• Law Enforcement 5 years
• NAC
Optional checks can include: Credit, Military Personnel Record, citizenship,
BVS, Selective Service (males born after 12/31/59), CIA, State Department.
NOTE: A NACI + Credit maybe utilized for Low Risk ADP and low level
financial related position or equivalent contractor staff on the SF-85P form.
(Same as NACI)
• State criminal history repository (SCHR) checks for all states of
residence
Other coverage elements, such as a credit search are available by request, or
when certain background conditions exist.
A reinvestigation for position requiring an initial CNACI is recommended every
10 years.
2
ANACI
(Same as NACLC)
• Employment 5 years
• Education 5 years and highest degree verified
• Residence 3 years
• References (not mandatory)
• Law Enforcement 5 years
• NACs
• Law Enforcement (by Record if not covered by Inquiry)
Credit 7 years
3&4
SSBI
• PRSI (Personal Subject Interview)
• Employment 7 years
• Education 7 years and highest degree verified
• Residence 3 years
• References 4 minimum, 2 developed
• Law Enforcement 10 years
• Court Records 10 years
• Former Spouse 10 years
• Citizenship
• Subject and legal status of foreign-born family
• Spouse/Cohabitant National Agency Checks (NACs)
• Credit 7 years
• NACs
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FPPS
CODE
TYPE OF
INVESTIGATION
SCOPE: EXPLANATION OF INQUIRY
5
MBI
(Same as NACI)
• Employment 5 years
• Education 5 years and highest degree verified
• Residence 3 years
• References (not mandatory)
• Law Enforcement 5 years
• NACs
Additions to standard NACI
• PRSI (Personal Subject Interview)
•
Credit 7 years
2 & 5
LBI
Primarily conducted for Moderate Risk Public Trust or Non-Critical Sensitive
positions with a moderate risk high point component. Example: Secret clearance
for an individual with a position risk designation of Moderate with a high range
of points as determined by the risk designation process.
(Enhancement of MBI but coverage is personal not via inquiry)
• Employment 3 years
• Education 1 year and highest degree verified
• Residence 1 year
• References (not mandatory)
• Law Enforcement 5 years
• NACs
• PRSI (Personal Subject Interview)
• Credit 7 years
Additions to MBI
• Court Records 5 years)
6
Background
Investigation
(BI)
(Enhancement of LBI, coverage is personal not via inquiry)
• Employment 5 years
• Education 5 years and highest degree verified
• Residence 3 years
• References (not mandatory)
• Law Enforcement 5 years
• NACs
• PRSI (Personal Subject Interview)
• Credit 7 years
• Court Records 5 years)
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FPPS
CODE
TYPE OF
INVESTIGATION
EXPLANATION OF INQUIRY
2
NACLC
(Same as NACI)
• Employment 5 years
• Education 5 years and highest degree verified
• Residence 3 years
• References (not mandatory)
• Law Enforcement 5 years
• NACs
Additions to standard NACI
• Law Enforcement (by Record if not covered by Inquiry)
• Credit 7 years
3 & 4
Single Scope
Background
Investigation –
Periodic
Reinvestigation
(SSBI-PR)
This is the required reinvestigation for Top Secret clearances and SCI access
conducted every 5 years. The SSBI-PR meets the requirement of EO 12968.
• PRSI (Personal Subject Interview)
• Employment 5 years
• Education 5
• Residence 5 years
• Law Enforcement 5 years
• Court Records 5 years
• Former Spouse 5 years
• References
• Subject, Spouse/Cohabitant National Agency Checks (NACs)
• Citizenship (Subject and legal status of foreign-born family, if not
previously covered)
6
Periodic
Reinvestigation
(PRI)
This reinvestigation is primarily conducted for High Risk positions usually
conducted every 5 years. Coverage includes:
• PRSI (Personal Subject Interview)
• References
• Law Enforcement 5 years
• Credit 5 years
• NACs
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Illustration 2
Minimum Investigative Requirements for National Security Positions
Position
Sensitivity
Designation
Level
Security Form
Required
Investigation
*
Required
Reinvestigation
Special-
Sensitive
Compartmented
Information
(SCI)
SF-86
Single Scope
Background
Investigation
(SSBI)
Every 5 Years –
Single Scope
Background
Investigation –
Periodic
Reinvestigation
(SSBI-PR)
Critical-
Sensitive
Access
SF-86
Single Scope
Background
Investigation
(SSBI)
Every 5 Years –
Single Scope
Background
Investigation –
Periodic
Reinvestigation
(SSBI-PR)
Critical-
Sensitive
SF-86
Background
Investigation
(BI)
Every 10 Years –
National Agency
Check with Law
and Credit
(NACLC)
Non-critical-
Sensitive
SF-86
Access National
Agency Check
and Inquiries
(ANACI)
*
Every 10 Years –
National Agency
Check with Law
and Credit
(NACLC)
* NOTE: The Public Trust component of the position risk/sensitivity designation may
require a higher-level investigation.
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Minimum Investigative Requirements for Law Enforcement Positions, per 446 DM 2
Position Sensitivity
Clearable for
Access
Security
Form
Required
Investigation
Required
Reinvestigation
Critical-Sensitive
(446 DM 2.3A,
Permanent Law
Enforcement
Positions)
Secret
SF-86
Background
Investigation
(BI)
Every 5 Years –
Periodic
Reinvestigation
with Residence
Coverage
(PRIR)
Critical-Sensitive
(446 DM 2.3B,
Temporary/Seasonal
Law Enforcement
Positions)
Secret
SF-86
Limited
Background
Investigation
(LBI) by
Agreement with
OPM (Upgrade
to BI when
employees
convert to full-
time permanent
status)
Each year, prior
to
commissioning,
a returning
temporary law
enforcement
officer must
have a National
Agency Check
(NAC)
conducted by
OPM
Minimum Investigative Requirements for Public Trust Positions
Position Risk Designation
Level
Security Form
Required Investigation
High Risk
SF-85P
Background Investigation
(BI)
Moderate Risk
SF-85P
Minimum Background
Investigation (MBI) **
Low Risk
Low Risk and contact with
children
SF-85
National Agency Check plus
Inquiries (NACI)
Child Care NACI
Reinvestigation
recommended at 10 year
intervals.
** Bureau/Office may require an LBI for its employees based upon OPM guidance for position
risk designation for some Moderate Risk positions.
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Illustration 3
U.S. DEPARTMENT OF THE INTERIOR
REQUEST FOR WAIVER OF PRE-APPOINTMENT INVESTIGATIVE REQUIREMENT
FOR A CRITICAL-SENSITIVE POSITION
ORIGINATING OFFICE
___________________________________________________________________________________________
__
NAME/ TITLE PROPOSED
POSITION
___________________________________________________________________________________________
__
ORGANIZATION PROPOSED EOD (DATE)
A waiver of pre-appointment investigative requirement is being requested for emergency reasons and such action
is necessary in the national interest. A justification for this request is attached. If approved, I will ensure the
individual will not have access to any classified national security information prior to the granting of a national
security clearance (if a requirement of the position). Forms required for the investigation were submitted to the
Bureau/Office security officer on ________________ (date).
___________________________________________________________________________________
__
IMMEDIATE SUPERVISOR SIGNATURE & DATE PRINTED NAME
___________________________________________________________________________________________
__
HIGHER LEVEL SUPERVISOR SIGNATURE & DATE PRINTED NAME
BUREAU/OFFICE HUMAN RESOURCES/ PERSONNEL OFFICER
Based on my review of the individual’s previous employment record and knowledge of this candidate’s
background, there appears to be no derogatory information which would preclude employment in a Critical-
Sensitive position pending completion of the required investigation.
___________________________________________________________________________________________
__
SIGNATURE & DATE PRINTED NAME
BUREAU/OFFICE SECURITY OFFICER
The results of the mandatory checks listed in 441 DM 5, or for law enforcement positions the results of the
mandatory Pre-appointment Background Check in 446 DM 2, are attached.
___________________________________________________________________________________________
__
SIGNATURE & DATE PRINTED NAME
HEAD OF BUREAU/OFFICE – APPROVAL - except
(Director, DOI-OLES for Law Enforcement positions)
___________________________________________________________________________________________
__
SIGNATURE & DATE PRINTED NAME
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ATTACHMENTS: (1) JUSTIFICATION FOR THIS REQUEST, AND (2) RESULTS OF MANDATORY CHECKS
ORIGINAL: EMPLOYEE’S OPF
cc: EMPLOYEE’S SECURITY FILE – 1
DI-1912
(Rev. 1/07)
Illustration 4
U.S. Department of the Interior
Pre-appointment Background Check
Report Number: __________________ Date:
__________________________________________
Subject: Pre-Employment Screening
Name: _________________________ DOB: ____________________ SSN:
___________________________
Address:
____________________________________________________________________________________
Marital Status: ___________________ Position Applied For:
________________________________________
CHECKS
• Drivers License (Verification of Record) : Yes ____ No ____
• OPM/Security Investigation Index (SII): Yes ____ No ____
• Military Records: Yes ____ No ____
• National Crime Information Center: (NCIC) Yes ____ No ____
(Law Enforcement Applicants
only)
• Local Law Enforcement Agencies Yes ____ No ____
• Credit History Yes ____ No ____
• Employment History Yes ____ No ____
• Residence History Yes ____ No ____
• Education/Training Yes ____ No ____
• References: Yes ____ No ____
• Other Checks/Information: Yes ____ No ____
___________________________________________________________________________________________
__
Subject Interview (narrative):
___________________________________________________________________________________________
__ Report Conducted By: Report Concurred By:
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___________________________________ ____________________________________
Print Name & Signature HR / Personnel Security or Security Officer
Personnel or Security Officer
___________________________________ ____________________________________
Date & Office Telephone Number Date & Office Telephone Number
Note: *ATTACHMENTS: List all pertinent reference material (including results of interviews, record checks,
vouchers, etc.) and attach a copy of all available documents.
DI-1990
(Rev. 1/07)