Active Public Trust Clearance: Vetting, Reciprocity, Revocation

An active public trust clearance is shorthand for holding a federal civilian or contractor position right now that required a favorably adjudicated background investigation under 5 CFR Part 731. It is a fitness or suitability finding tied to your current job, not a security clearance, and not a credential you carry independently of employment.¹ It covers access to sensitive but unclassified systems and data in roles that affect public safety, finances, or government programs. Keeping it active depends on staying in a covered position, passing ongoing checks, and understanding what happens when you change jobs or when something in your record shifts.

What “Active” Actually Means

Three words get used almost interchangeably in job postings and resumes, and the differences matter when you try to move.

Active. You currently occupy a position that requires the designation, and your investigation is favorably adjudicated. Work continues without interruption.
Current. Your investigation was completed and favorably adjudicated, but you are no longer in a covered position. A new agency can often pick it up without starting over, if there has been no extended break in federal service.
Expired. Enough time has passed since your last covered position that a gaining agency would need to initiate a fresh investigation. Executive Order 13488 does not require agencies to honor a prior favorable determination when the individual has had a break in employment since that determination was made.²

Continuous employment in a covered position keeps the designation active. Leave that position and the status turns into something a future employer may or may not accept.

Public Trust Is Not a Security Clearance

This confusion causes real problems on resumes and in hiring conversations. A security clearance (Confidential, Secret, or Top Secret) grants access to classified national security information, uses the SF-86, and covers at least ten years of personal history. A public trust determination uses the SF-85P, covers seven years, and grants access to sensitive but unclassified information.¹ If a posting lists “Public Trust” under security requirements, it is asking for a background investigation, not a clearance.

One boundary worth naming: low-risk (non-sensitive) positions using the SF-85 are not technically public trust positions. The public trust label applies to moderate-risk (Tier 2) and high-risk (Tier 4) roles under 5 CFR 731.106, which cover policy-making, public safety and health, law enforcement, fiduciary responsibilities, or other duties demanding a significant degree of public trust.³ If your current job is low risk, you do not hold public trust status, whatever a recruiter may have said.

Continuous Vetting Keeps It Active

The old five-year reinvestigation cycle is being phased out. Under the Trusted Workforce 2.0 initiative, the government has moved to continuous vetting: ongoing automated checks against criminal databases, financial records, and other government data sources instead of a scheduled full reinvestigation.⁴ The regulation at 5 CFR 731.106(d) now provides that continuous vetting for a public trust position satisfies the periodic reinvestigation requirement under Executive Order 13488.⁵

For someone with an active designation, this changes the calculus in two ways. There is no predictable reinvestigation date to prepare for. And a DUI, a tax lien, or a new arrest can surface in near real-time and trigger scrutiny rather than sitting quietly until the next scheduled review. The system rewards consistently clean conduct rather than the ability to tidy up before a deadline.

What Can Jeopardize an Active Designation

5 CFR 731.202 lists the factors adjudicators weigh when deciding suitability. No single factor is automatically disqualifying. Adjudicators evaluate the seriousness of the conduct, how recent it was, your age at the time, and evidence of rehabilitation. The factors are:

Criminal conduct, including arrests, charges, and convictions.
Dishonest conduct, including fraud, theft, and financial dishonesty. This category also covers lying or omitting information on the SF-85P, which adjudicators often treat as more damaging than whatever was concealed.
Material false statement in the application. Only OPM can take action based on this factor.
Illegal drug use without evidence of rehabilitation. Current illegal drug use disqualifies you regardless of state marijuana laws. Past use is evaluated case by case.
Excessive alcohol use in a pattern that suggests inability to perform duties or a safety risk.
Misconduct or negligence in employment, including being fired for cause or a pattern of poor performance tied to conduct.
Violent conduct, whether or not it resulted in criminal charges.⁶

Financial problems alone do not disqualify you, but they draw attention. Adjudicators look for patterns suggesting irresponsibility, vulnerability to coercion, or dishonesty. A medical bankruptcy handled responsibly reads very differently from years of ignored collection notices. Full disclosure and evidence that you are managing the situation carry weight.

Reciprocity When You Change Agencies

Moving to a new federal agency or contractor while your designation is active is the cleanest scenario. Executive Order 13488 generally requires the gaining agency to accept your prior favorable determination rather than starting over, provided three conditions are met: the gaining agency uses equivalent fitness criteria, the prior determination was based on equivalent standards, and you have had no break in employment since that determination was made.² A 2025 OPM memorandum reinforced that agencies must apply reciprocity for individuals with existing favorably adjudicated investigations and directed agencies to seek three-day completion of vetting in qualifying reciprocity cases.⁷

Reciprocity has exceptions. A gaining agency can refuse to honor your prior determination if the new position requires a higher-level investigation than what you previously underwent, if new information has emerged that calls your fitness into question, or if your investigative record shows conduct incompatible with the new role’s duties.² Some agencies also apply their own independent vetting standards or require polygraphs and will decline to accept another agency’s determination. Ask the gaining security office early whether they will accept your current investigation or need to initiate a new one. Do not resign your covered position until you have that answer in writing.

If the Agency Moves to Take It Away

An unfavorable action can include cancellation of eligibility, removal from your position, cancellation of reinstatement eligibility, or debarment from federal employment for up to three years. The agency must notify you in writing and explain the basis for the decision.⁸

You have the right to appeal a suitability action to the Merit Systems Protection Board. The filing deadline is generally 30 days from the date you receive the agency’s decision. Miss the window and you can forfeit the right to appeal entirely.⁹ One distinction matters here: if the agency framed its decision as a “fitness” determination rather than a formal “suitability” action, MSPB jurisdiction may not apply, and your appeal routes narrow considerably. Consult a federal employment attorney quickly if you receive an unfavorable notice, so you know which route is available before the clock runs down.

Appeals that succeed generally show that adjudicators failed to consider mitigating factors, that the conduct was not recent or serious enough to justify the action, or that you were denied proper procedural protections. Simply disagreeing with the outcome, without new evidence or a procedural error to point to, rarely works.

1
USAJOBS Help Center. What Are Background Checks and Security Clearances?
2
GovInfo. Executive Order 13488 – Granting Reciprocity on Excepted Service and Contractor Employees
3
eCFR. 5 CFR 731.106 – Designation of Public Trust Positions and Investigative Requirements
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Defense Counterintelligence and Security Agency. Continuous Vetting Enrollment Begins for Non-sensitive Public Trust Federal Workforce
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eCFR. 5 CFR 731.106 – Designation of Public Trust Positions and Investigative Requirements
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eCFR. 5 CFR 731.202 – Criteria for Making Suitability Determinations
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Office of Personnel Management. Streamlining Vetting Processes in Support of the Merit Hiring Plan
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U.S. Office of Personnel Management. Suitability Adjudications
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U.S. Merit Systems Protection Board. How to File an Appeal