Trusted Workforce 2.0 has sparked major progress on security clearance and personnel vetting reform, but there's still plenty of big challenges left.
The government’s personnel vetting system — the process of conducting background investigations and granting security clearances to millions of federal employees and contractors — appeared to be in deep trouble.
It was the spring of 2018, and the background investigations backlog had hit a record-high 725,000 cases. It was taking the National Background Investigations Bureau hundreds of days to conduct background investigations, leading to lengthy wait times to fill cleared jobs in government and industry.
The Office of Personnel Management, which housed NBIB, was still reeling from a pair of 2015 data breaches. Suspected China-linked hackers had stolen the background investigation files on 22 million individuals.Despite the turmoil, behind the scenes, officials were preparing to formally launch one of the most sweeping and consequential personnel vetting reform effort in at least 50 years. The new initiative, called “Trusted Workforce 2.0,” would seek to address the government’s lengthy and byzantine personnel vetting process by modernizing the underlying policies and technologies.
“They were talking on the one level about these far-reaching policy implementations and reforms, but yet, they had this nightmare of a fight on their hands with the OPM breach and the big backlog,” Donald Blersch, a former senior government security official who now leads the Intelligence and National Security Alliance’s Security Policy Reform Council, said in an interview. “Everything was still based on the old systems, driven primarily by paper and very labor-intensive.” 
The push to modernize the background investigation process was driven by the “Performance Accountability Council,” a high-level group of leaders from OPM, the Office of Management and Budget and the Office of the Director of National Intelligence.
Valerie Kerben, an independent consultant and former senior policy advisor at ODNI, said the push from the top was a key ingredient to Trusted Workforce 2.0. Kerben also served as chief of policy and collaboration within the National Counterintelligence and Security Center.
“Everybody realized there were so many conflicting and complex policies,” Kerben said in an interview. “There was the backlog, and some of the background investigative methods were kind of antiquated. We’re coming into the technology age. Let’s figure out how we become more efficient with better data sources and data checks done electronically.”
The Trusted Workforce 2.0 has survived multiple presidential transitions and yielded historic reforms to the personnel vetting process. Yet seven years later, major challenges remain to establishing a modern, streamlined personnel vetting system.
“This is one case where I think all elements, both in the private sector and in the public sector, have come together to make some major reforms that’ll help us not only get people through the system, but just to make it much more effective overall,” Blersch said. “But the crucial implementation piece is really continuing to get into high swing.”
Continuous vetting and DCSA
The first phase of Trusted Workforce 2.0 involved reducing the deep security clearance backlog. Part of the solution was sheer manpower — NBIB hired thousands of new investigators to work down the caseload.
But the government also began to embrace new technologies. NBIB began letting investigators use video teleconferencing, for instance, to reach security clearance applicants in certain scenarios.
“I’ve been in the security business a long time; we’re scared to death of telephones and VTCs and that kind of stuff,” Charlie Phalen, the then-director of the NBIB, told Federal News Network in a 2019 interview. “It took a little while to get over that, but we are over that. What this has done is really improve access to get information resolved. It has improved our ability to reach out to places that are harder to get otherwise.”
Agencies also transitioned to a new model for monitoring cleared employees called “continuous vetting.”
Traditionally, employees would have to go through a background investigation every 5 or 10 years. Called a “periodic reinvestigation,” it mirrored in many ways the same exhaustive process that employees had to go through when they first entered government. And it had become a major drain on investigative resources.
Furthermore, in between investigations, clearance holders were required to report any new developments that could impact their access to classified information.
“But what was found is, individuals forgot to report, such as things like marital status, foreign travel, arrests, financial and civil actions against them,” Kerben said. “So the objective for government to doing continuous vetting is, it’s an ongoing proactive check that could be done behind the scenes when items arise for risk-based decisions.”
ODNI’s National Counterintelligence and Security Center began developing continuous vetting years before the launch of Trusted Workforce 2.0. Instead of needing investigators to pull records manually, the continuous vetting system relies on records databases and technologies that have only become available in recent decades. The system of automated checks alerts security officials to potential red flags, like a suspicious financial transaction or an arrest.
Under Trusted Workforce 2.0, officials made the adoption of continuous vetting a whole-of-government priority. By 2021, the Defense Department had completely replaced periodic reinvestigations with continuous vetting. Civilian agencies are now adopting the system of automated record checks as well.
The widescale adoption of continuous vetting allowed DCSA to focus its investigators on new cases, rather than periodic reinvestigations.
The first phase of Trusted Workforce 2.0 also involved transitioning the background investigation mission from OPM to DoD. The Trump administration directed the transfer of NBIB into the Defense Security Service. The merger created a new organization, the Defense Counterintelligence and Security Agency, that conducts 95% of background investigations across government.
By early 2020, just a few months after the White House formally established DCSA, the background investigations backlog had been whittled down to a “steady state” of 200,000 cases.
“It was super collaborative,” Blersch said of the initial phase of Trusted Workforce 2.0. “And it’s a little cliche, but in my 30 years of working lots of different interagency efforts, it’s a really good example of government working at its best. People kind of left their egos at the door and really rolled up their sleeves trying to figure out how to fix this.”
Policy updates and SF-86 revamp
The Trump administration launched Trusted Workforce 2.0 and shepherded it through phase one. The Biden administration took the reins of the initiative in 2021, and shaped many key policy reforms under what became phase two.
In 2022, the PAC released “Federal Personnel Vetting Guidelines” that laid out the fundamental principles behind the Trusted Workforce 2.0 model. It established a three-tier investigative model, condensed from the previous five, that segmented the different investigative tiers into low, medium and high, depending on the sensitivity and risk of the job.
The PAC published “Federal Personnel Vetting Performance Management Standards” that set ambitious new targets for how long it should take to complete background investigations and adjudications.
“This would be wild,” Senate Intelligence Committee Chairman Mark Warner (D-Va.) said about the new standards during a 2022 hearing with PAC officials. “You get there, you’ll never get any grief from me, because it’s so much shorter.”
The Biden administration also took steps to replace the venerable Standard Form-86, the longstanding form for security clearance applicants.
In 2024, the Office of Management and Budget approved a new “Personnel Vetting Questionnaire.” The PVQ will replace the SF-86 and other standard forms filled out by government personnel applying to national security and public trust positions.
The new questionnaire streamlines and updates several of the old forms. For instance, it features new language around the applicant’s prior use of marijuana, to make clear that the government views past use of cannabis differently than other drugs.
And it also includes key updates on an applicant’s mental health history to reduce the stigma around seeking counseling and other care. Officials have sought for years to combat the perception that mental health challenges will automatically derail a person’s access to classified information.
“The question was rephrased to really focus on only those specific conditions that can impact someone’s judgment and reliability,” Kerben said. “And the messaging that came out was an emphasis on wellness and recovery, and that it’s positive to go for counseling. It shows a good faith effort of treatment and rehabilitation, and it shouldn’t affect someone’s job … that was a big shift in trying to inform the public not to be intimidated coming into the government, and that mental health counseling is important.”
NBIS and the future of Trusted Workforce 2.0
Despite progress on the backlog, the establishment of DCSA, and the numerous landmark policy updates, the Trusted Workforce 2.0 initiative still faces significant challenges.
Last year, DCSA’s backlog began creeping up for the first time in years. It’s led to longer wait times for security clearance investigations.
Meanwhile, most insiders agree that the successful development of the National Background Investigation Services system is the key to successfully reforming the personnel vetting system in the long term. And DCSA faces major challenges with NBIS.
Launched in the aftermath of the OPM breach, the NBIS system is intended to provide a modern, end-to-end personnel vetting IT system. NBIS will include critical vetting data on millions of federal employees and contractors. It’s supposed to provide agencies with access to that data on an as-needed basis, streamlining the process for employees to move between jobs.
“When someone comes into the government, they go through vetting — a background investigation, an adjudication — those processes should be uniform across the board,” Kerben said. “It should be the same investigative standards, the same adjudicative standards, and if an individual is found eligible to have a security clearance, it should be easy for them to move around to a similar position at another agency. That is a big focus of Trusted Workforce: rapid on-boarding, greater mobility, tailored vetting and a new agency not having to do duplicative work before a person goes to a new position.”
But DCSA has run into numerous development challenges with NBIS that are familiar to many big government IT projects. The system has struggled with both requirements and program management. It’s now years behind schedule and hundreds of millions of dollars over budget. More than eight years after launching, NBIS has delivered little in the way of new capabilities.
DCSA is now working on a revamped program plan to get NBIS back on track. One of the initial goals is the successful integration of the new Personnel Vetting Questionnaire into NBIS.
Ultimately, the IT system will be crucial to what DCSA Director David Cattler has called a “data-centric” future for the security and counterintelligence agency. Cattler took over as director last year. He has sought to right the ship on NBIS, while revamping the agency’s strategy for the future.
“In addition to being a security services provider, we are a data-centric agency,” Cattler said in an interview last year. “We do have that tremendous amount of information that we maintain, and all these very unique relationships with certainly the defense industry, but also all across government. And one of the central questions I’m asking is, are we wringing all the potential value out of that pool of data today? And what else can we do?”
Blersch said despite the challenges with NBIS, the implementation and build out of continuous vetting has already been a successful first step for the future of personnel vetting.
While the challenge used to be obtaining information about security clearance applicants, Blersch said the conundrum today is what to do with all the data that investigators can now collect. DCSA and other agencies are now looking to AI to help connect the dots.
“That’ll be a big help looking at trends and having the tools flag things that even 1000 investigators looking through the data wouldn’t necessarily make the connection,” Blersch said. “It’s still going to be up to a person who is trained and certified to make decisions. But we just become richer as we fold those tools and information in.”
