Navigating Federal Background Investigation Requirements in the VA

Size: px

Start display at page:

Download "Navigating Federal Background Investigation Requirements in the VA"

Berniece Bond
5 years ago
Views:

the VA Joshua Blockburger Director, Security &

1 Atlanta, Atlanta, GA Dec 9-11, GA 2014 Navigating Federal Background Investigation Requirements in the VA Joshua Blockburger Director, Security & Investigations Center Department of Veterans Affairs

2 Safe and Secure Environment Employees Contractors Affiliates Veterans Visitors 2

Operations, Security, and Preparedness Operations Emergency Management National Security Planning Integrated Operations Center (IOC) Security and Law Enforcement Police Services Vulnerability

3 Operations, Security, and Preparedness Operations Emergency Management National Security Planning Integrated Operations Center (IOC) Security and Law Enforcement Police Services Vulnerability Assessments Law Enforcement Training Center Personnel Security and Identity Management Preparedness Major Initiative Homeland Security Presidential Directive 12 Personnel Security and Suitability Background Investigations and Adjudications 3

4 It s about trust that you are who you say you are, and that you are the type of person that we want on our team Atlanta, GA Safe and Secure Environment Personnel Security 4

5 Identity, Credential, and Access Management (ICAM) 5

6 Personnel Security Background Investigations Executive Order and 5 CFR 731, 732 and 736 provide that all Federal appointments are subject to investigation VA Directive 6500 requires background investigations prior to physical and/or logical access including contractors VA Directive 0710 requires National Agency Check with Written Inquiries (NACI) conducted by Office of Personnel Management (OPM) for low risk/non-sensitive positions HSPD-12 requires NACI at a minimum for Personal Identity Verification (PIV) badge issuance 6

Homeland Security Presidential Directive 12 HSPD-12 signed in August 2004 VA suspense for 100% Personal Identity Verification (PIV) card issuance March 2012 Office of Management and Budget

7 Homeland Security Presidential Directive 12 HSPD-12 signed in August 2004 VA suspense for 100% Personal Identity Verification (PIV) card issuance March 2012 Office of Management and Budget (OMB) memorandum requires HSPD-12 compliance by FY12 for physical and logical access use of PIV and non-piv card VA Directive 0735 dated February 2011; VA Handbook 0735 in final coordination 7

8 Personnel Security Risk and Sensitivity Designations Personnel Designation Automated Tool (PDAT) Low Risk = National Agency Checks with Written Inquiries (NACI) Moderate Risk = Minimum Background Investigation (MBI) (Ex. Police Officers, HR Specialists, Contracting Officers/Specialists, Accountants, Claims Examiners, Computer Specialists) High Risk = Background Investigation (BI) (Ex. High Level Managers, Financial Managers, HR Managers, Police Chiefs, IRM Chiefs, Certain Computer Specialists) 8

Continuous Readiness for Information Security Program (CRISP) A cultural change that is necessary for VA to achieve adequate protection of Veterans and other sensitive information Protect the trust

9 Continuous Readiness for Information Security Program (CRISP) A cultural change that is necessary for VA to achieve adequate protection of Veterans and other sensitive information Protect the trust relation with every Veteran Promote key habits in all VA personnel Optimize Information Security Privacy and Information Security Training Contractor Rules of Behavior Training Management System (TMS) 9

10 Risk Level Atlanta, GA Investigative Requirements Low Risk (NACI) Moderate Risk (MBI) Impact Low Moderate to Severe Severe Interview No Yes Yes Employment, 3 years 5 years 5 years Education, Law Residence(s) 3 years 3 years 3 years Credit No 7 years 7 years High Risk (BI) Reinvestigation No 5 years 5 years 10

11 Suitability / Fitness Character traits and conduct sufficient to decide if an individual is likely or not likely to be able to carry out the duties of a Federal job with appropriate integrity, efficiency, and effectiveness. Misconduct or negligence in employment Criminal or dishonest conduct Material, intentional false statement or deception or fraud in examination or appointment (OPM only) Refusal to furnish testimony as required (OPM only) Alcohol abuse direct threat to property/safety Illegal use of narcotics/drugs/controlled substances Knowing and willful engagement in acts of activities to overthrow the U.S. government 11

12 Adjudication Reasonable expectation that a person's employment would promote the efficiency and effectiveness of the service Basic suitability adjudication of conduct as it impacts on a person's suitability for a position with government Position risk suitability in terms of the public trust risk level of the position - the higher the level of public trust, the more serious an issue becomes Position performance suitability is an assessment of the present or potential impact (nexus) of the conduct or issues on a person's efficient service in the position 12

13 Positions that are temporary and limited to 6 months or less either single or do not exceed an aggregate of 6 months; Purchase and hire employees appointed for 6 months or less; Without Compensation (WOCs), student trainees, work study and Intergovernmental Partnership Act (IPAs) appointed 6 months or less OR more than 6 months without access to computer, patient, or sensitive information; Contract personnel with appointment less than 6 months with or without access to computer, patient or sensitive information OR appointment 6 months or more without access to computer, patient or sensitive information; Medical and dental residents with less than 1 year of continuous service; Volunteers Personnel Security Special Agreement Checks 13

Pre-Contract Hiring Background Investigation Process

initiates and employee completes COR sends to VA SIC for

Fingerprints (electronic) EQIP Signature Cards Employee

14 Pre-Contract Hiring Background Investigation Process Contract Award Company provides names to COR CLIN VA initiates and employee completes COR sends to VA SIC for review/release VA releases to OPM; OPM schedules Fingerprints (electronic) EQIP Signature Cards Employee releases VA adjudicates Special Agreement Check (SAC) HSPD-12 access granted 14

15 How long does all of this take? Action Low Risk Mod/High Risk Initiate 22 days 29 days Investigate 40 days 102 days Adjudicate 25 days 27 days End-to-End 87 days 158 days VA has implemented the following to expedite Additional staff and training Streamlining processes Electronic initiation and delivery (and potential future OPM prototype for electronic adjudication) Working with companies and CORs to train and assist 15

16 Pitfalls/Problems and Solutions Employees not completing forms in timely manner Company should insist employees complete ASAP EQIP need experienced help = call /4490 Employees need to ensure releasing in EQIP with all required signatures, resume, and fingerprints complete Employees might be eligible for reciprocity CORs are working with VA to enable reciprocity for like investigation on file with OPM and no breaks in service Ensuring access for contractors during process VA policy requires SAC adjudication prior to access and OPM scheduling prior to PIV 16

17 How Can I Help? Leverage your own HR processes to align with federal government requirements; look at pre-award hiring with your HR team Help to review eligibility for reciprocity and provide self-certifications if applicable Provide names to COR immediately after contract award and notify COR if names change Help your employees with the EQIP requirements process and have them complete and release as soon as they can 17

18 What Can I Expect from VA? VA CORs working with your company to ensure timely initiation within EQIP Timely adjudication of Special Agreement Check (SAC) fingerprint checks against national databases Timely review, release, and scheduling of the investigation with OPM Getting your people to work with physical and logical access as soon as possible given the government s requirements to ensure safe and secure environment Final adjudication of federal background investigation, recording the adjudication with OPM, and notification to company through CORs 18

OMB Memo 11-11 dated February 2011 and SECVA Memo dated April 2011 mandate use

Access Control System (LACS) Physical Access Control System (PACS) What happens

19 OMB Memo dated February 2011 and SECVA Memo dated April 2011 mandate use of card in FY12 It s about interoperability it s a federal credential Logical Access Control System (LACS) Physical Access Control System (PACS) What happens if I forget my card? I forgot my PIN! What about visitors? My badge doesn t work!!! 19

20 Safe and Secure Environment It s about trust 20

21 Questions or Comments? 21

United States Department of Health & Human Services Office of the Assistant Secretary for Administration and Management

United States Department of Health & Human Services Office of the Assistant Secretary for Administration and Management U.S. Department of Health & Human Services Handbook Guide For Personal Identity Verification