The Future Personnel Vetting IT System is Called NBIS

Originally published at: The Future Personnel Vetting IT System is Called NBIS | ClearanceJobs Blog

The Defense Counterintelligence and Security Agency (DCSA) is in the process of building an Information Technology (IT) system for personnel vetting to replace the systems currently in use by various agencies. This new system is called the National Background Investigation Services (NBIS) and it will include all of the steps in the background investigation cycle…

If anything goes wrong the computer did it.

“I, for one, welcome all of the changes that were a long-time coming.”

I believe your statement is shortsighted Marko.

Continuous vetting or continuous evaluation in my opinion will never work long term in the clearance industry. The entire foundation of continuous evaluation hinges upon the clearance holder self reporting things throughout his/her time as a clearance holder like a divorce, civil action, financial debts, foreign contacts, foreign travel, etc.

There are always going to be clearance holders (more than you can imagine) that don’t self report what they are required to do and will get away with it in a reinvestigation or through the continuous evaluation process. As an Investigator it’s amazing the things you uncover when you actually sit down (in person hopefully in the future) and meticulously go through someone’s SF-86 asking each question while that person has been put under an unsworn declaration and reminded of the Title 18 Section 1001 law.

I cannot begin to tell you over the last 15 years doing background investigations how many things are uncovered in reinvestigations with clearance holders that have held clearances for 20+ years forgetting to list things on the Security Questionnaire due to their ineptness, laziness, and sometimes dishonesty in completing the SF-86. One thing I continuously develop are other employments and self-employments that require coverage that weren’t originally listed on the Questionnaire. Now why wouldn’t someone list an employment or period of self employment on the Questionnaire? Sometimes it’s because they are lazy and don’t think it’s necessary even though it’s a requirement and other times (usually this is the real reason), it’s because they were terminated from the employer or left under unfavorable circumstances so they didn’t want to list it which falls under an integrity issue. Even with self employments I have developed with people, sometimes people don’t list their self employment because I discover they aren’t even filing their taxes with their self employment income which is considered a violation of law to not report self employment income with a business.

Marko…I truly believe you are living in this utopian world thinking continuous vetting or evaluation will actually work along with ODNI and all of the other federal agencies that have agreed to do CE without having a periodic reinvestigation and an Investigator actually doing the interviews, then you will be sorely mistaken just as these federal agencies will be when things slip through the cracks. The possibilities are endless of what will slip through the cracks by not doing a thorough federal background investigation even for reinvestigations. I cannot even begin to tell you what is developed and issues discussed when simply doing routine source interviews at someone’s employer or record checks at an employment.

Surely the federal government has thought through all of this…correct? Surely the government isn’t going to pin their hopes on all clearance holders being honest…wouldn’t you think?

I don’t share this same utopian vision because I am the boots on the ground working the cases and seeing the laziness and dishonesty in people reporting required information on a Questionnaire.

What will happen if something slips through the cracks and a clearance holder that shouldn’t get their clearance does because of the continuous vetting process is in place and an Investigator isn’t personally questioning this individual and doing follow up source and record interviews? I sure as heck don’t want to find out! Is the clearance process perfect by having Investigators doing a reinvestigation and a Subject Interview, source interview, and record interviews? The answer is No, however, it is a much better solution than doing nothing at all and hoping people self report and that a few routine random criminal record checks helps keep people honest and reporting required information.

I for one am concerned about the clearance process going forward and don’t share your same sentiments Marko. I think if you actually picked up a Pen and paper and did a Subject Interview you’d realize how important Subject interviews are to the investigation process. In fact adjudicators can see this also as they read the reports so they can vouch for what is going on when they see these investigative reports. You were once an Adjudicator weren’t you Marko?? certainly you can recall the discrepancies and issues developed time and time again when Investigators did interviews with Subjects.

Unless you know what experience I have in PERSEC perhaps you should not assume that I have not done ALL the things involved in background investigations. No system is perfect and this will not catch 100% of the concerns. I have caught many things myself through cross referencing. The old PRs also did not catch 100% of the issues, Everyone has a viewpoint based on their own experiences, there is no right or wrong answer, only the goal to be more efficient and enable those who need clearances to get them expeditiously. CE will require boots on the ground to follow up on issues and interview subjects as needed. We can agree to disagree on some things and agree on others professionally.

I know you’ve claimed to have adjudicator experience so that’s why I made the point that you more than likely have seen the amount of discrepancies and issues developed even during routine re-investigations of someone with a clearance.

My prior post being straightforward to you was just describing what the “boots on the ground” see on most occasions when conducting federal background investigations. I also speak to adjudicators on occasion that work in PERSEC offices and they comment on the amount of issues and discrepancies that Subject Interviews, Source Interviews, and record interviews uncover when Investigators do a thorough job of conducting federal background investigations. Not every Investigator does a thorough job or is asking all of the questions. This is not an easy job and one must take it with a lot of seriousness when conducting federal background investigations for security clearances or that Investigator fails to provide a thorough and quality product.

Based upon the research and what I’ve read about CE, it simply doesn’t pass the eye test or sniff test in uncovering issues, discrepancies, and vetting someone for a clearance on a periodic basis.

My research tells me that CE does routine credit checks and criminal history checks. The remainder of the vetting process relies upon the person to self report. If they don’t self report, they say the consequence is that the clearance can be revoked or terminated.

However, this relies upon people self-reporting. This doesn’t happen on a regular basis. Poor FSO programs that don’t train or teach people what to report isn’t helping either, but the fact remains that the clearance process now relies upon an honor system.

Newsflash, there are probably 25% or more of people (unsure how to quantify this but I see this regularly) that aren’t being honest in completing the Security Questionnaire or at a minimum or being lazy and haphazard in being thorough. So how is CE going to catch the employment issues, reprimands, etc. that aren’t being investigated through CE? My understanding is that CE isn’t doing routine employment record checks unless there is a known reported issue on the SF-86. Does this process really believe everyone will report employment misconduct, reprimands, etc.? It won’t happen.

Anyways this is just my two cents but I doubt that Investigators were asked for input into this CE process. Investigator are seen as simply a “cog in the wheel” of the machine even though the Investigator and the actual investigation is the most important part of the entire process that allows the rest of the process to run smoothly and for the adjudicator to have all of the necessary information to make an informed decision on what to do on a clearance decision. The decisions of CE in my opinion are made in a vacuum and far from the input of those that are the “boots on the ground” uncovering issues, discrepancies, dishonesty, and laziness from applicants during the clearance process.

I guess my point in contending with some of your points in all of your recent articles about CE in the last few years is you don’t speak about the things that can be missed in a clearance process because of CE. You only share your opinion that it will be better and it’s a long time coming to have CE or this is the correct process to conduct reinvestigations by CE.

But has anyone ever down a thorough analysis on what can be potentially missed by not doing in person interviews with a Subject and meticulously going through the SF-86 like we used to do asking every question, reading verbal and body language all while that person is under an Unsworn Declaration and advised of Title 18 Section 1001?

Until I see an article on this blog website that discusses the pro’s and con’s of CE and looks at the potential impacts of CE missing things that weren’t missed in the previous process, I’ll continue to have skepticism about what you are writing.

I think you are a knowledgeable individual about the clearance process and I am not trying to pick a fight but have valid and serious concerns about the background investigation process going forward within the federal government.

To all for your reading pleasure. Also note that CE is not waiting 5 to 7 to 10 years before a PR is initiated, it is designed to catch things when they happen or within a lesser amount of time. There are many things about CE that are not made for public consumption, so to say it does not work would not be an accurate statement. Other contributors have provided their take:

I included this one specifically to show the same concerns are addressed previously and are being worked:

I’ll admit I did not read all the TL;DR but I think this statement is incorrect. The idea is that a lot of this activity will be detected by periodically checking online databases. Maybe not foreign contacts so much, but everything else on that list will pop up in one database or another.

what are your referring to as TL /DR?

“The idea is that a lot of this activity will be detected by periodically checking online databases. Maybe not foreign contacts so much, but everything else on that list will pop up in one database or another.”

Oh really? So is CE going to pull every single employment record during CE within scope of their coverage period? Are we really relying upon databases to uncover all adjudicative criteria in a federal background investigation?

Subject Interviews, Source Interviews, and record checks are the investigative tools needed and required to obtain relevant and factual information coupled together with database checks of criminal history and credit. One should not replace the other. All of these things should operate together to create a comprehensive and thorough investigative product.

So do I disagree with you that online databases are the answer to doing background checks? Absolutely. Yes I do.

About the only thing I agree with the CE implementation is that we should be conducting field work and interviews as things happen in real time. As things are discovered during the clearance process things should be reported by the clearance holder and followed up on. That part of CE is a good thing. These are good methods of security practices and protocols.

What I disagree with is removing the periodic reinvestigation as part of a Subject Interview, source interviews, and record reviews, etc. when conducting field work on periodic reinvestigations as a whole unless something triggers or is self reported because as I already stated many things will not be uncovered or reported if we rely upon an honor code system or a few database checks that are conducted. In person and thorough interviews with applicants and clearance holders asking all of the pertinent adjudicative questions and following up with additional questions to include full resolution of issues/concerns are the tried and true methods to conduct these federal background investigations.

One of your articles that you provided discuss the problems we should do to avoid another Aaron Alexis situation when a clearance holder accessed government facilities and opened fire causing many deaths and mayhem. Well, here we are. We should consider retaining our investigative processes and not try to reinvent the wheel here. I know the old process wasn’t 100% fool proof. I am not advocating that it ever was. In fact, the results of the Alexis investigation showed flaws in how the field work was conducted and the Seattle Police Department wouldn’t release records about Alexis’ criminal past and issues and mental health wasn’t followed up on either it appears as it should have been. However, imagine if the Investigator could have interviewed Alexis when these issues were being discovered or follow up with the reports from co-workers on the issues they raised about his paranoia and mental health issues. We potentially could have avoided the things he did that day by removing his clearance access. In addition, the adjudication failed in granting and renewing him for his secret clearance.

What should have happened is Alexis should have been interviewed regularly as issues were being discovered and developed on him which is the good part of what CE can do if it finds criminal hits on individuals. The part I don’t like or where CE has flaws or fails in it’s designed purpose is that they are no longer going to be doing regular Subject Interview, source interviews, or record interviews unless something triggers in a criminal history database or unless it is self reported. Well if someone isn’t self reporting information because of the issues they don’t want others to know about so that they can avoid losing a clearance or a job, wouldn’t it be a good idea at a minimum to be doing a Subject Interview on clearance holders on a periodic level and putting them under an Unsworn Declaration and advised of Title 18 1001 so that information can be discussed, developed, and followed up on?? Why only take something away like regular interviews and routine record searches only to replace that with self reporting only and database searches which is a huge part of what CE purports to be? Why not use both in conjunction one with another? Seems counterintuitive to not use all processes we have at our disposal.

Is CE also designed to cut costs and save money? If that is a big part of the process, then please let me know. I’ve always said that you get what you pay for in life. If you want quality things, you have to pay for quality things…this includes even federal background investigations if you want them on very thorough and high quality level you have to pay for them.

It is helpful to note that CE/CV are supplemental tools to the PERSEC process. CE/CV isn’t replacing anything, per se, but it is eliminating the ridiculous idea that once someone is cleared, they don’t need to be investigated for another 5 years.

I’m glad for CE/CV. There is still a lot of riffraff to root out of the cleared space.


None of the articles you posted speak to the concerns I raised with regards to CE skipping the process of conducting Subject Interviews, personal source interviews, or employment record interviews during the reinvestigation process as I have stated. The information I have gathered and researched primarily states that CE replaces the old periodic reinvestigation to enrolling clearance holders to a continuous monitoring of databases checking credit reports, checking criminal history databases, and relying upon self reporting to conduct their CE process.

During the CE process, an actual PR can be created where they actually put boots on the ground and do a background investigation and actually follow up with source interviews, record checks, and a Subject Interview, however, I have yet to see one case or investigation from CE come into my queue since CE has been in place and I am independently contracted with numerous federal agencies to include direct federal contracts. So to conclude that CE has replaced the old T5R and Phased PR and SSBI-PR is an understatement as Investigators are seeing little to no field work when it comes to CE of clearance holders because everything is being operated within CE to include routine or random database checks and self reporting which will not catch many issues and concerns that can come up during the clearance process.

We shall not beat a dead horse here. We don’t make policy- ODNI does! We follow what the powers that be tell us to do. This topic is closed.

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