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Maintaining a Personnel Security Clearance

Maintaining the Personnel Security Clearance record in JPAS is the responsibility of the industrial contractor.

Classified Information Nondisclosure Agreement (SF-312)

An FSO must brief employees on non-disclosure requirements prior to granting access; NISPOM Paragraph 3-105 requires that an individual issued an initial personnel security clearance for the first time execute a Classified Information Nondisclosure Agreement (SF-312) prior to being granted access to classified information and that the completed form is forwarded to the cognizant security agency for retention. If JPAS reflects an SF-312 was previously executed, it is not necessary to complete another form.

The date entered in JPAS should be the date the employee signed the form and it should not be changed. Other dates may be present in JPAS for the SF-312 execution but these dates should not be changed as they are used by DISCO retrieve SF-312s from the archives.

After the FSO has their employee complete an SF-312, it should be mailed to DISCO for retention:

Defense Industrial Security Clearance Office
600 10th Street
Fort Meade, MD 20755

FSOs will be notified and a new SF-312 will be required for any SF-312 not meeting the following criteria:

  • Employee Social Security Number is incomplete or omitted
  • Signature of employee is typed or omitted
  • Witness signature is typed or omitted
  • Employee and witness signature dates must be the same

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Maintaining the PID (Personal Identification Data) information

Changing PID information when industry employees have DoD Categories

Industry is unable to modify a record in JPAS to correct Personally Identifiable Information (PII) such as name or date of birth if the record has one or more active DoD categories.

  • If the person does have an active relationship with the DoD person category, e.g. active duty, reservist, civilian, etc., the person should contact their Personnel Support Detachment (PSD), Human Resources Office (HRO), or Personnel Center to affect this change. The PID information in JPAS is being fed from the information on file with the PSD, HRO or Personnel Center. Once the PSD, HRO or Personnel Center information is current the security officer should be able to verify the PID change in JPAS.
  • If the person does NOT have an active relationship with the DoD Person category, but the DoD category is showing as active on the record in JPAS, please submit a Research. Recertify or Upgrade (RRU) Request to the Defense Industrial Security Clearance Office (DISCO). The RRU submission should contain information pertaining to the PID change and the date this person separated affiliation with the DoD person category.
    • A data manipulation request will be sent to effect the PID change in JPAS.
    • Efforts will be made to have the DoD Person Category post a separation date in JPAS which will enable Industry to modify the record for future changes.

Please Note: The Defense Eligibility Enrollment Reporting System (DEERS) is not a personnel center and cannot make PII-related JPAS modifications. The JPAS Help Desk cannot assist in the correction of PID.

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SSN Changes

FSOs can make changes to personal identification data with the exception of the SSN. When an SSN change is required, the request must be submitted to DISCO using the Research request. Do not build the new SSN into the JPAS prior to requesting the change. The SMO should pull the person into their Personnel Security Management (PSM) Net and update the Person Category with the Industry Category, Classification and Cage Code.

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Alias – Add, Modify or Delete

An authorized JPAS user can add, modify, and delete an alias for a person. The following guidance should be used when entering or modifying the alias for a person:

  • Do not enter an alias if the person's last name and first name match and the alias name only reflects an initial for the middle name
  • Do not enter an alias if it is a single name (e.g. Cher, short for Cheryl)
  • Do not enter nick-names
  • When changing the person's name, always enter the prior name used as an alias unless the name already exists in the record.

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Marital Status

The FSO should notify DISCO when an employee changes marital or cohabitation status in the following situations:

  • If there is a change in marital or cohabitation status of an employee who is in process for a clearance with an investigative basis of: Single Scope Background Investigation (SSBI); Single Scope Background Periodic Reinvestigation (SBPR); or Phased Periodic Reinvestigation (PPR).
  • If an employee has a scheduled or open investigation type of National Agency Check/Local Agency Check/Credit Check (NACLC) and their change in marital or cohabitation status is to a foreign national only.

The FSO should submit a Recertify request to provide the notification, to include the date of the change and reason for the change, e.g., marriage. This will minimize any disruption to the investigative process.

No update is required if an employee marries a foreign national when there is no open investigation unless it pertains to an SCI clearance. That change of marital or cohabitation update will occur during the next periodic reinvestigation.

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Incident Reports – what, when and why

The FSO should submit reports for personnel with a security clearance, in-process for a clearance, or a that have a clearance eligibility that could be reinstated, in accordance with the reporting requirements in paragraph 1-302 of the National Industrial Security Program Operating Manual (NISPOM). JPAS provides the incident report capability to facilitate this reporting. At this time, the FSO should mark report as "final" rather than "initial".

It is strongly recommended incident reports be submitted via JPAS. The system was designed to accommodate incident reporting. Submitting incidents via JPAS provides immediate assurance of receipt and eliminates the manual handling by multiple individuals when hard copy requests are received and entered into JPAS by adjudication staff.

To facilitate quicker processing of incident reports, the report must include the basic information covering "who" (who was involved; for example: subject, law enforcement agency, court name), "what" (what is/was the incident), "where" (where did the incident happen; for example: city, state), and "when" (when did the incident occur). When submitting an incident report, refer to the questions on the SF86 relating to the incident and provide as much of the information as possible relative to those questions.

An adjudicator will review the submitted report and determine if the item may be closed and a new eligibility adjudication entered, or if a partial investigation is required to provide the adjudicator sufficient information to make an adjudication. After the incident report is reviewed by the adjudicator, the FSO may receive a request for the person to submit a new SF 86, Questionnaire for National Security Positions; this does not happen in all cases. If such a request is made, the FSO should initiate the request to the employee using JPAS. If the request is not received by DISCO within 30 days from the date of request, DISCO will administratively withdraw the eligibility determination by changing the eligibility to Loss of Jurisdiction. At that time, all access must stop.

Sources from which an incident report may be received:

  • Facility Security Officers (FSO)
  • Other Government Agencies
  • Investigative process
  • Another CAF's decision to Deny, Revoke or Suspend a (Federal) security clearance
  • Anyone who knows the person

If there is a question on the ability for the person to have continued access when an incident report is reflected, contact the DoD Security Services Center for assistance.

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Investigation Status Checks

JPAS should be used to check on the status of a pending investigation. If the FSO does not yet have access to JPAS, the status of an employee's investigation may be checked by calling the DoD Security Services Center. Do not call OPM for status checks.

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Mass Personnel Changes

This feature enables authorized users in one action to take mass actions. The types of mass actions include:

  1. separate (terminate) the association;
  2. separate and transfer personnel associations among multiple facility organizations (MFO);
  3. separate and transfer non-MFOs; or
  4. transfer to non-MFOs. Items 2 and 3 overlay the category and will create a history item for the action; item 4 adds an additional person category to the person's record, i.e. adds a new affiliation to the person.

After performing a mass change, a check should be completed to ensure that all actions were accomplished. If an open incident report exists or the access is suspended, the person's record will not be modified. There are additional restrictions for Key Management Personnel (KMP) since the FCL may be affected. Verify from the Ineligible Personnel list the actions that the system did not complete.

Other helpful processing hints include:

  • When using the mass action capability, access downgrades are based on the organization's eligibility and not the person's eligibility. This also applies when moving access to another organization.
  • Only United States (US) and North Atlantic Treaty Organization (NATO) accesses can be downgraded. For example, SCI access can not be downgraded in a mass action.
  • DISCO receives notification when a mass personnel change is affected on an individual with an open investigation. Individuals will appear on the Ineligible Personnel List within the Mass Personnel Changes screen. Manual processing of these actions is required. No further notification to DISCO is required for individuals with an open investigation.
  • Notify DISCO when an action is pending on a person, e.g. pending incident report, pending adjudication and pending investigation request (not an open investigation). A Research request should be submitted on persons with pending actions to indicate the type of action that is required.
  • The Separation type "Facility Termination" should only be used when the organization's eligibility has been terminated.
  • When personnel appear on the Ineligible Personnel List and are identified as KMPs, you must complete the action by using the Add/Modify non-DoD Person screen. As a reminder, changes in the status of KMPs are still reportable to your Industrial Security Representative in accordance with the National Industrial Security Program Operating Manual (NISPOM), 1-302h item 3.
  • A history action is created for an organizational change.

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Research, Recertify, and Upgrade Actions (June 2012)

Do not submit Research, Recertify, Upgrade (RRU) for status inquiries, except in the circumstance provided in 1c and 3a, as this only delays the processing of other RRUs. If you have a status-type question not meeting the requirement of 1c or 3a that you are unable to resolve please contact the DoD Security Services Center.

A JCAVS User within the submitting SMO can cancel a previously submitted RRU. However, the RRU cannot be cancelled once it has been assigned to a JAMS user. Once cancelled, a JCAVS user can submit a subsequent RRU. JPAS will not permit generation of an RRU if there is an existing RRU on a person.

The following matrix can help determine which type of Research, Recertify, Upgrade (RRU) to select when submitting to DISCO:

 

Research (1)

Recertify (2)

Upgrade (3)

A.

When unable to modify a record in JPAS to correct Personally Identifiable Information (PII), e.g., name or date of birth, if the record does NOT have an active Owning or Serving DoD Person Categories1

To notify DISCO of an unavoidable delay in compliance with an official DISCO request for information or documentation (deployed, e-QIP link not showing in JPAS, etc.)

Request the status of an Investigation / Incident Report if notification is not received within 30 days of the Investigation close date or DISCO's receipt of the Incident Report2

B.

If a person has multiple records in JPAS and a record requires deletion

Request deletion of erroneous DoD/Mil/Civilian person category created by FSO

Change in SCI eligibility requirements with an open investigation or pending adjudication at DISCO3

C.

Submit a status request if notification is not received within seven days after faxing information to DISCO to satisfy an official request

Request for DISCO to close an open investigation line which continues to reflect in JPAS subsequent to investigation close or adjudication

Request to continue an OPM discontinued investigation within four months (If over four months a new investigation must be initiated)

D.

Notify DISCO once separation date is posted in JPAS under the following conditions:

  1. Investigation closed and pending adjudication
  2. Incident report pending

Notify DISCO to cancel scheduled investigation when the subject no longer requires access to classified information and separation date is not posted

Request for DISCO to accept reciprocity from another agency that has granted a Confidential, Secret or Top Secret Eligibility. (For SCI eligibility, DISCO can only accept reciprocity at a Top Secret level)4

E.

Respond to an official request by DISCO (CAF Message, not JPAS report) for submission of Periodic Reinvestigation (PR) when a PR is not required based upon the following:

  1. PR is not required due to person's current level of Access
  2. PR is being conducted by another government agency
  3. There is an unavoidable delay in complying with the DISCO request

Submit a request when any of the following occur:

  1. Change to person's Social Security Number (SSN) in JPAS
  2. Change in marital/cohabitation status if an investigation is ongoing
  3. Marriage/cohabitation to/with a foreign national

Request to recertify a previous VALID eligibility by DISCO that has been overlaid with a lower eligibility

F.

 

 

Request upgrade or downgrade of an ongoing investigation

General RRU Guidance to Industry

The following guidance is provided to assist Industry in the submission of Research, Recertify, and Upgrade requests:

  1. If a person has an active Owning or Servicing relationship (to include access) with the DoD person category, e.g. active duty, reservist, civilian, etc., the person should contact their Personnel Support Detachment (PSD), Human Resources Office (HRO), or Personnel Center to affect a PII change. The PII in JPAS is being fed from the information on file with the PSD, HRO or Personnel Center. Once the PSD, HRO or Personnel Center information is current the security officer should be able to verify the PII change in JPAS.
  2. DISCO processes the majority of Investigations within 30 days of OPM close date.
  3. Provide the Cognizant Security Agency when SCI eligibility is required.
  4. Provide the specific agency name, type and date of investigation from which the eligibility is based.

Note:

  • NACI investigations are valid for "Favorable" Eligibility regarding Position of Trust (IT-ADP III). DISCO is unable to grant clearance eligibility for National Security positions based on a NACI.
  • DISCO cannot upgrade a Secret eligibility to Top Secret based on a NACLC / ANACI.
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Separation from the company

Upon separation from the organization, the FSO enters a separated date for the employee in the system. If an investigation is open for the employee, a notification will be forwarded to the appropriate CAF to determine whether the investigation needs to be cancelled. Notify DISCO via Research request when a separation occurs and either of the following two items exist. Notification will permit DISCO to take appropriate actions on the record.

  • An action is pending on a person, e.g. pending incident report, pending adjudication and pending investigation request.
  • There is not an open investigation and an interim eligibility exists

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SMO Relationships in JPAS when Sensitive Compartmented Information (SCI) access is involved

  • Procedures have not yet been standardized across DoD on how to handle JPAS owning and servicing relationships when SCI access is involved.
  • The owning activity is responsible for maintaining the individual's clearance record.
  • If your organization provides the SCI indoctrination, then your organization should take the JPAS user level 2 or 3 owning relationship with the individual and the Government Activity may take a servicing relationship. This will permit both organizations to receive eligibility change notifications. If your organization does not provide the SCI indoctrination, then your organization should take a level 2 or 3 servicing relationship and the Government Activity will take the owning relationship. It is recommended that you discuss with your Government Activity the procedures they prefer.
  • When completing requests to initiate investigations, annotate the investigation request in one of the following areas to indicate the need for SCI (or SAP) adjudication. identify the unclassified SCI/SAP name in the contract number section, or have the person identify the information in the remarks section of the Personnel Security Questionnaire.
  • For AF SCI eligibility determinations, an SCI SMO must be recorded on individual's clearance record that requires the SCI determination. Failure to reflect the SCI SMO will mean that the AF CAF will not process the request.

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