How to Get a Public Trust Clearance: SF-85P, Fingerprints, Adjudication

To get a public trust clearance, you need a federal job offer for a moderate- or high-risk position, and then you complete the Standard Form 85P through your sponsoring agency, submit fingerprints, and cooperate with a background investigation that verifies your history over the past seven years. There is no way to start the process on your own. And despite the common name, a public trust determination is not a security clearance: it authorizes you to hold a sensitive federal role without granting access to classified national defense information.¹ The rules come from 5 CFR Part 731, and the lookback for most questions runs seven years.

You Need a Job Offer First

The process begins when a federal agency or government contractor selects you for a position that requires a public trust determination. The sponsoring agency initiates the investigation by giving you access to the electronic questionnaire. Without a specific job tied to your name, there is no mechanism to request the screening.

Most public trust roles require U.S. citizenship, though some agencies permit lawful permanent residents when the individual has skills critical to the mission. Your work authorization is verified through the standard Form I-9 process that applies to all federal hires.²

If you already hold a favorable public trust determination from a prior federal position, you may not have to repeat the full process. Under the Trusted Workforce 2.0 framework, the government has been working to improve reciprocity between agencies.³ In practice, it is not automatic. The new agency may still review your file and could require additional investigation if the earlier determination was for a lower risk level or a significant amount of time has passed.

Step 1: Confirm the Risk Level and Investigation Tier

Every federal position is assigned a risk level based on how much damage an unsuitable employee could cause. Under 5 CFR 731.106, positions designated as moderate or high risk are public trust positions.⁴

Moderate risk positions trigger a Tier 2 background investigation, which is narrower in scope and involves fewer in-person interviews.⁵
High risk positions require a Tier 4 investigation, which is broader and more closely resembles a security clearance investigation in depth.⁵

You will find the risk level in the job announcement, usually on USAJOBS under the “Security clearance” or “Position sensitivity and risk” section.¹ Knowing which tier applies tells you how deep the investigation will go and helps you anticipate whether interviews with references and neighbors are likely.

Step 2: Gather Your Records Before You Open the Form

The biggest mistake applicants make is opening the questionnaire before they have collected their records. The form asks for exact dates, addresses, and contact details going back seven years, and guessing produces discrepancies that investigators flag. Spend a few days pulling this together first.

You will need:

A complete residential history with street addresses and move-in and move-out dates for every place you have lived during the coverage period, plus the name and contact information of someone who can verify each address.
Every job, period of unemployment, and stretch of self-employment during the coverage period, along with supervisor names and current contact information.⁶
Names and locations of any schools attended after high school, with dates of attendance.
Personal references who have known you well during the coverage period and are not family members. Former roommates, longtime friends, and colleagues work well. Collect their full names, current phone numbers, and email addresses.

If you cannot remember an exact month you moved into an apartment six years ago, provide your best estimate and note that it is approximate. What you should never do is omit something because you think it looks bad.

Step 3: Pull Your Credit and Address Financial Issues

The financial section trips up more applicants than any other part of the process. The questionnaire asks about delinquent federal debts, tax liens, bankruptcy filings, and accounts in collections.⁶ Before you begin, pull your credit reports from all three bureaus and review them. That is where you will find collection accounts you may have forgotten and debts you thought were resolved.

If you have a bankruptcy in your history, locate the filing date, case number, and court where it was filed. For any outstanding debt, know the original creditor, current balance, and what you have done to address it. The existence of debt is not automatically disqualifying. Adjudicators are looking for a pattern of irresponsibility or a vulnerability that could be exploited. Active repayment plans, resolved tax balances, and documented efforts to address obligations all weigh in your favor. Ignored debts with no plan attached are where applicants get into trouble.

Step 4: Complete the SF-85P in eApp

The Standard Form 85P, titled the Questionnaire for Public Trust Positions, is the primary form for moderate and high risk public trust investigations.⁶ Your sponsoring agency will provide access to the electronic system where you complete it. As of 2025, the Defense Counterintelligence and Security Agency transitioned from the older e-QIP system to the NBIS eApp platform for submitting investigative forms including the SF-85P.⁷

Omissions are treated far more seriously than the underlying issue because they suggest dishonesty, and dishonesty is one of the suitability factors adjudicators evaluate. Investigators pull your records independently, and any gap between what you reported and what they find will require explanation. Use the comment fields to add context for anything negative. If you had a stretch of unemployment, explain the circumstances. If you were arrested, describe what happened and what you have done since. Adjudicators are trained to look at the whole person, and thoughtful explanations carry real weight.

Step 5: Answer the Drug Questions Truthfully

The SF-85P asks whether you have illegally used any drugs or controlled substances in the last seven years, including marijuana.⁶ The form also covers illegal purchase or trafficking, misuse of prescription drugs, and any counseling related to drug use. A critical note printed on the form itself: your truthful answers to the drug questions cannot be used as evidence against you in a criminal proceeding.

Past marijuana use, even in a state where it is legal, is evaluated under federal law, where it remains a controlled substance. OPM guidance makes clear that past marijuana use is not automatically disqualifying. Agencies must evaluate drug involvement case by case, considering the nature and seriousness of the conduct, the circumstances, how recently it occurred, and evidence of rehabilitation.⁸ Occasional use years ago is a different position than use last month. Current illegal drug use is a much harder problem, and current users are generally considered unsuitable. If you are still using, stop well before beginning the application.

Step 6: Fingerprints and the Investigation

Once you submit your questionnaire through eApp, the formal investigation begins. Most applicants provide fingerprints at a federal facility or authorized location so the FBI can run a criminal history check. From there, the scope depends on your tier.

For a Tier 2 investigation, investigators primarily verify records and check databases: credit, criminal history, and employment. For a Tier 4 investigation, those checks are supplemented by personal interviews.⁵ Investigators may speak with neighbors, former employers, and the references you listed. You may also be called in for a subject interview to clarify details about your financial history, foreign contacts, or past conduct.

Timelines vary. Straightforward cases can resolve in a few months; cases involving extensive foreign travel, unresolved financial issues, or hard-to-reach references take longer. Some agencies grant interim or temporary entry on duty while the full investigation runs, allowing you to start working before the final determination. Whether this happens depends on the agency and the initial results of your records checks.

What Adjudicators Look For

The suitability factors are spelled out in 5 CFR 731.202. They are:

Misconduct or negligence in employment
Criminal conduct
Material false statement, deception, or fraud in the application or examination process
Dishonest conduct
Excessive alcohol use without evidence of rehabilitation, to a degree that would impair job performance or threaten safety
Illegal use of drugs without evidence of rehabilitation
Knowing and willful engagement in acts designed to overthrow the U.S. Government by force
Any statutory or regulatory bar that prevents lawful employment in the position
Violent conduct

These are the only factors that can be used to find you unsuitable.⁹ Notice the recurring phrase “without evidence of rehabilitation” next to alcohol and drug use. The regulation builds in room for people who had problems and addressed them, which is why documentation of treatment, counseling, or sustained behavioral change carries so much weight. Adjudicators also consider the seriousness of the conduct, the circumstances, how recently it occurred, your age at the time, and whether there is a pattern or an isolated incident.

If You’re Denied

An unfavorable determination is not necessarily the end. Before it reaches a final decision, most agencies will notify you of the specific concerns and give you an opportunity to respond. Take that period seriously. Providing proof of debt repayment, completion of substance abuse treatment, or character references from employers can change the outcome.

If the final decision is still against you, the Merit Systems Protection Board has jurisdiction over appeals of adverse suitability determinations. You must file within 30 calendar days of receiving the agency’s decision. If you and the agency agree in writing to alternative dispute resolution, the deadline extends to 60 days. Appeals are filed with the MSPB regional or field office that covers where you live, either electronically through the e-Appeal Online system or by mail. You will need to include the notice of proposed action, the agency’s final decision, and related personnel documentation. You can represent yourself or designate someone to represent you in writing.¹⁰

After You’re Approved: Continuous Vetting

A favorable determination is not a one-time event. Under Trusted Workforce 2.0, the government has moved from periodic reinvestigations to continuous vetting for public trust positions. Agencies were required to enroll their full non-sensitive public trust workforce into continuous vetting by September 30, 2025.¹¹

Continuous vetting runs automated checks against criminal, financial, terrorism, and public records databases on an ongoing basis.¹² When the system flags something, investigators assess whether the alert warrants further review. Outcomes range from no action, to working with you to resolve the issue, to suspension or revocation of the favorable determination in serious cases. A new arrest, a sudden accumulation of unpaid debt, or unreported foreign contacts can trigger a review at any time, so the standards that got you approved keep applying for as long as you hold the position.

1
USAJOBS Help Center. What Are Background Checks and Security Clearances?
2
U.S. Citizenship and Immigration Services. I-9, Employment Eligibility Verification
3
Performance.gov. Trusted Workforce Policy Index
4
eCFR. 5 CFR 731.106 – Designation of Public Trust Positions and Investigative Requirements
5
National Institutes of Health. Understanding U.S. Government Background Investigations and Reinvestigations
6
U.S. Office of Personnel Management. Questionnaire for Public Trust Positions
7
Defense Counterintelligence and Security Agency. NBIS eApp and Agency
8
U.S. Office of Personnel Management. Federal Laws and Policies Prohibiting Marijuana Use
9
eCFR. 5 CFR 731.202 – Criteria for Making Suitability Determinations
10
U.S. Merit Systems Protection Board. How to File an Appeal
11
U.S. Office of Personnel Management. Streamlining Vetting Processes in Support of the Merit Hiring Plan
12
Defense Counterintelligence and Security Agency. Continuous Vetting