Policy Questions
Click on the questions below to see the answers to the FAQs.
Must reinvestigations be conducted to keep PIV credentials valid?
If there is a NACI on record that is over 15 years old, does a new NACI have to be submitted?
Can a National Agency Check with Law and Credit (NACLC) be used for PIV credential issuance?
-answers
If there are employees and contractors working for another Federal agency working on contracts or services that support the tenant agency, can a PIV be issued by the agency whose property they work on or does the PIV have to be issued by the employing agency. Example: GSA provided maintenance support working in the building but the GSA office is not on site.
The authorization for card issuance should originate with the employing agency (or contracting agency in the case of contractors). However, there is nothing to prohibit one agency from providing issuance services to another agency in accordance with interagency MOA/MOU.
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Does HSPD-12 require that a PIV credential be issued before a new employee is granted any access to Federal facilities or information systems?
No. Agencies may, at their discretion, issue new employees temporary ID badges for access while PIV enrollment and card issuance is in process. These temporary badges must be physically and electronically distinguishable from PIV credentials.
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Can a PIV card be used by other organizations for other purposes (e.g., access to private facilities, identification for airline travel)?
HSPD-12 and FIPS-201 do not impose any restrictions on the use of the PIV card as an identity credential.
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Is a Special Agreement Check (SAC) necessary or recommended in order to fulfill the FIPS 201 investigative mandate?
No. The investigative requirements set forth in FIPS 201 state: "…The process shall begin with initiation of a National Agency Check with Written Inquiries (NACI) or other Office of Personnel Management (OPM) or National Security community investigation required for Federal employment…" A SAC investigation will not meet the requirements of FIPS 201.
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Can agencies use other investigative service providers in lieu of OPM to conduct the investigations required by FIPS 201?
No, unless an agency has original or OPM delegated authority to conduct background investigations. Contractor investigations must follow FIPS 201 and agency employee investigation processes.
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Must reinvestigations be conducted to keep PIV credentials valid?
No. PIV credentials do not require reinvestigations to remain valid. Agencies must, however, continue to comply with the reinvestigative requirements set forth in the national security investigative standards.
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For employees and contractors hired prior to October 27, 2005, if the agency has maintained records indicating the investigative requirements (including fingerprint check) were completed for these individuals, and they were successfully adjudicated, then these employees and contractors will not need to complete a new NCHC. However, for any employees or contractors hired on or after October 27, 2005, agencies should maintain a copy of the prints (either the full set or just the two prints required by FIPS 201) so a biometric match may be conducted in the future as necessary. Additionally, as agencies implement their enrollment stations during FY2007 and FY2008, they must ensure these employees and contractors are in full compliance with FIPS 201 Section 4.4.1, particularly the requirement that fingerprints taken during the PIV enrollment action "shall be used for one-to-many matching with the database of fingerprints maintained by the FBI." This ensures that fingerprints taken during the same enrollment action are used for the PIV Card templates and the FBI National Criminal History Check of the PIV applicant.
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If a person has had a "break in service" (i.e., left a job for which they had to be investigated to meet FIPS 201 requirements), must a new investigation be conducted for that person to receive a new PIV credential?
If the "break in service" is two years or more, a new investigation must be conducted before a PIV credential can be issued. In accordance with Executive Order 12968, if the break in service is less than two years, an updated security questionnaire should be completed and any admitted issues resolved as appropriate.
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If there is a NACI on record that is over 15 years old, does a new NACI have to be submitted?
While there is no requirement for a NACI to be renewed, there must be a record on file indicating the employee or contractor has completed at least the minimum background check requirements. If an employee or contractor completed the NACI process and records cannot be located, the individual would need to undergo the NACI (or equivalent) process again.
Note that many employees and contractors will have background checks superior to a NACI (e.g. LBI); in these cases the individuals would not need to complete the NACI process as long as there is a record that the investigative requirements were met.
An exception to the above requirements occurs when there is a break in service of over two years. In this case, an individual would need to undergo a new background check.
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Can a National Agency Check with Law and Credit (NACLC) be used for PIV credential issuance?
The NACLC is often used as the minimum investigative requirement for access to Secret information and below for military service personnel and Federal contractors. For purposes of PIV credential issuance, the NACLC satisfies the essential requirements.
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How do I verify whether or not a NACI (or equivalent) has already been completed on an existing employee or contractor?
Authorized personnel security offices may get this information directly from the OPM investigations database. If an agency's personnel security office does not have access, they should contact OPM's Agency Liaison Group at 703-603-0442. Additionally, older "Official Personnel Folders" contain SF-86s and SF-171s bearing a stamp which usually reads "Investigated to 10450 standards". Agencies may take this as evidence a NACI was completed.
