Guidance on Submitting Periodic Reinvestigations
Effective December 1, 2015, the Defense Security Service (DSS), Personnel Security Management and Oversight for Industry (PSMO-I) will accept requests for periodic reinvestigations that are within 90 days of the investigation anniversary date. This is a change from the current 180-day timeframe.
Depending upon the level of access required, individuals holding security clearances are subject to a Periodic Reinvestigation (PR) at a minimum of every five years for Top Secret, 10 years for Secret*, and 15 years for Confidential. The Facility Security Officer is responsible for reviewing access records to ensure employees are submitted for PRs as required in the Personnel Security Program regulation.
NISPOM paragraph 2-201d states that contractors may be subject to a PR program as specified by the Cognizant Security Authority (CSA). Personnel security policy requires that contractors with access at the Top Secret and Secret levels be reinvestigated at 5 and 10 year intervals from the closing date of the previous investigation. Given that these dates are reflected in Joint Personnel Adjudication System (JPAS), and NISPOM paragraph 2-200b requires that contractors maintain the accuracy of their employees' access records, contractors are responsible for submitting the e-QIP for an employee's PR no later than the applicable due date.
To monitor compliance with PR submission requirements, VROC will run monthly reports of overdue PRs and request e-QIPs for the PRs. If the employee's e-QIP for a PR is not submitted within 15 days from issuance of the overdue notification, VROC will administratively downgrade the eligibility without prejudice in JPAS. If the employee requires the higher level eligibility, please submit the required PR and VROC will reinstate the eligibility. For individuals with no owning or servicing Security Management Office (SMO) identified in JPAS, VROC may enter an LOJ. The previous valid eligibility will be reinstated when the e-QIP is received by VROC. Contractors are reminded to access JPAS accounts weekly and check notifications.
Things to do prior to submitting the PR
Prior to submitting an individual for a PR, please ensure that the individual still requires a security clearance and at the same level. If you determine that an individual currently requires access only at a lower level of classification or no longer requires a clearance, please downgrade or terminate their access as necessary in JPAS.
If the employee is in process for a PR through another government agency
If the PR request was submitted to an investigative agency other than the Office of Personnel Management (OPM), please let VROC know via the JPAS Recertify request. This will prevent an NDM or LOJ for non-receipt of an overdue PR.
Fingerprint Cards for PRs
In accordance with ISL 2006-02, it is no longer necessary to submit fingerprint cards for any type of periodic reinvestigation unless specifically requested to do so. An exception: when the request is for a NACLC and the previous investigation was a NACLC or ANACI, the system will recognize and mark the request as a PR; therefore, no fingerprint cards are required. If the investigation is any other type for a NACLC PR, fingerprint cards are required because JPAS forwards the request as an initial request. However, if the PR request is for an individual with a break in service OPM highly recommends submission of a fingerprint card.
*Changed to 5 years under the tiered investigation policy adopted by the DNI but not yet implemented by the DoD.