As the Defense Counterintelligence and Security Agency (DCSA) has stated, it is important to note that “proper position designation is the foundation of an effective and consistent suitability and personnel security program." The type or level of investigation requested are directly related to the risk and sensitivity level to which the position is designated.
At the National Institutes of Health (NIH), Administrative Officers (AOs) undergo specific training to serve as authorized HSPD-12 Sponsors. AOs are required to complete training that includes signing a certificate submitted to the Homeland Security Presidential Directive (HSPD)-12 Program Office before any AO can have the authority to request a badge for an individual. As part of the training, it is stated that: “Under Title 18 of the U.S. Code, it is a federal offense to counterfeit, alter or misuse the HHS ID Badge and system, and AOs have a responsibility to contribute to privacy, security, and protection in the PIV system."
When entering individuals into NED, AOs must comply with all HSPD-12 guidelines and requests as an HSPD-12 Sponsor and remember the responsibilities and duties that come with being an AO. Therefore, AOs must enter individuals into NED with the correct tier level and proper position designation for DPSAC to conduct a proper investigation accordingly.
AOs should not be entering individuals at a lower tier with the hopes of onboarding the individual quicker, as that may not be true. When individuals are onboarded at a lower tier level (e.g., Tier 1) and then have their Position Sensitivity Level (PSL) upgraded once approved (e.g., Tier 3), the individual will be required to complete the background investigation process a second time (fingerprinting and investigation forms). This leads to longer processing times and doubles the amount of time and effort, as our staff in DPSAC will have to process the same individual again. Additionally, upgrading an individual's PSL, after the getting approved at a lower tier level, will cost their ICO additional funds to go through the background investigation process again. Lastly, if issues are discovered during the higher-level prescreening/investigation, then the individual may be found ineligible or unsuitable for their NIH position. If the individual is found ineligible or unsuitable, then the AO must deactivate the individual's NED record.
Not only are AOs responsible in honestly inserting information in NED, but AOs can save funds for their ICO and save processing time for the individual and for DPSAC by submitting individuals at the correct tier to begin with. DPSAC appreciates your cooperation in ensuring the NIH workforce is comprised of suitable federal employees, contractors and affiliates who promote the efficiency and integrity of the NIH mission and service. Thank you!
