Continuous Evaluation

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The Trusted Workforce 2.0 initiative will transform and modernize the archaic personnel vetting programs in dire need of change and efficiency.

 

By definition per Executive Order 13467, ‘Continuous Vetting (CV) is the on-going process to review the background of an individual who has been determined to be eligible for access to classified information or to hold a sensitive position at any time during the period of eligibility’. The Defense Counterintelligence and Security Agency’s (DCSA) goal within CV is to protect national security by mitigating potential risk and insider threat through a continual vetting process that leverages a set of automated record checks and business rules to assist in continuous assessment of an individual’s continued eligibility.

 

In its initial implementation during 2019 the program has resulted in 95,000 CV alerts. Of those alerts of adverse information found by CV 52% were self-reported, while 48% would not have been identified until the subject’s next PR was due. This represents an early warning process on personnel information that otherwise may not be reviewed for over 6 years for a Secret clearance and 1 year for a Top Secret. The overwhelming majority of alerts discovered were financial in nature, which speaks volumes about the state of personal finances in our present economy. This will present significant challenges for recruiting and staffing efforts in an already extremely tight job market. Augmenting and ultimately replacing periodic reinvestigations with a continuous vetting process may prove instrumental in reducing the existing backlog of security clearances and other investigations that currently hamstring agencies and industry’s manpower capabilities.

 

Continuous Vetting programs implemented by company within the Defense Industrial Base (DIB) can provide additional benefits to organizations outside of just clearance determinations. Just as with the government agencies employees, internal company CV specific programs will be evaluating signs of financial or personnel distress of their employees. Ideally, this will lead towards a better understanding of key stressors on their employee’s lives and how to focus company benefits and employee assistance programs more effectively to assist them in those challenges. Early engagement with personnel issues at the industry level will assist in ensuring a ‘trusted workforce’ for the U.S. Government, and may increase the safety and wellness of  company employees while reducing other risks like insider threat and workplace violence.

 

While implementing a program internally requires significant resources and capability, it also requires employees ‘buy in’ and trust. Enrollment in a corporate CE program may be a requirement for ongoing employment in order to raise ‘red flags’ for cleared and non-cleared populations, but effective employee communication is critical. CE also represents a significant cultural shift from a reactive periodic reinvestigation model to a more proactive ongoing evaluation of suitability checks. Clearance holders have been programed for years that as long as any ‘red flags’ are addressed by the time of their next PR then there will be no adverse information to discuss. Quite the opposite will be the reality moving forward whereby adverse alerts appear in real time. It is and always has been a clearance holder’s responsibility to report any adverse information based upon the 13 adjudicative guidelines. Defending a failure to report will be harder to adjudicate than if the information was disclosed.