Implementation of Suitability Reinvestigations for Tier 2 and Tier 4

The Suitability Reinvestigation Requirements in the Office of Personnel Management's (OPM) Title 5, Code of Federal Regulations section 731.106 (5 C.F.R. 731.106), 731.106(d) (1) requires incumbents of Public Trust positions to undergo Suitability reinvestigations at least once every 5 years. NIH's Division of Personnel Security and Access Control (DPSAC) has been going through a process of submitting and adjudicating reinvestigations for the NIH population occupying public trust positions at the T2 and T4 levels. Just over 26% of the NIH population (11,504 individuals) hold a public trust position. Of those, 47.2% (5,425 investigation) are due for re-investigation in 2022.


In June 2018, OPM issued a variation to the regulation at 5 C.F.R. 731.106 to temporarily extend the periodicity of public trust reinvestigation from 5 years to 7 years. However, as of April 2021, OPM has advised that the two-year extension period for reinvestigations of individuals at the T2 and T4 levels has expired, adjusting the interval for reinvestigations from 7 years back to 5 years. To help mitigate this process, DPSAC has begun the process to reinvestigate individuals who have investigations more than 5 years old.


Due to such changes, the adjusted interval for public trust reinvestigations will necessitate an increased need for reinvestigations among the NIH's population. When it is your turn, DPSAC will be engaging with your populations to begin the required reinvestigations and will appreciate cooperation in going through this process smoothly. These reinvestigations will require individuals to go through the investigative process including completing the e-QIP form and fingerprinting.

If you have any further questions regarding this process, please contact the DPSAC at ORSPersonnelSecurity@mail.nih.gov. Thank you for your cooperation.

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On December 5, 2022, the Department of Homeland Security announced an extension of the REAL ID full enforcement deadline to May 7, 2025. Learn more about the REAL ID Extension.​

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