HSPD-12 Background Check: Tiers, Forms, and Adjudication

An HSPD-12 background check is the federal suitability investigation you must clear before you can be issued a Personal Identity Verification (PIV) card and gain routine access to government buildings or federal computer systems. The depth of the check scales with your position’s risk level, but every applicant follows the same basic path: complete an electronic questionnaire, get fingerprinted, sit through an investigation run by the Defense Counterintelligence and Security Agency (DCSA), and wait for an adjudicator’s decision.

Who Has to Go Through It

The requirement is tied to access, not job title. All federal civilian employees and military members go through it. Federal contractors and their employees fall under the same mandate whenever they need routine physical access to government-controlled buildings or logical access to federal networks and databases.¹

Short-term workers are treated differently. Under OPM’s credentialing standards, employees with assignments lasting fewer than six continuous months are not automatically subject to full HSPD-12 credentialing; the agency makes a risk-based decision about what level of vetting fits.² Seasonal and intermittent employees whose affiliation runs beyond six months don’t count as short-term, even if their schedules are irregular.³

Which Tier of Investigation Applies to You

The federal government uses a tiered system, and two tiers cover most HSPD-12 credentialing.

Tier 1 is the baseline for non-sensitive, low-risk positions. It replaced the older National Agency Check with Inquiries (NACI). A Tier 1 investigation checks FBI criminal history records, federal agency databases, and sends written inquiries to previous employers, schools, references, and law enforcement in the places you have lived. Tier 1 is the minimum required for PIV card issuance.⁴

Tier 2 covers moderate-risk public trust positions and replaced the former Minimum Background Investigation (MBI). It includes everything in Tier 1 and adds a credit check and, in most cases, a personal interview.

Positions involving national security, law enforcement, or access to classified information require higher-tier investigations beyond what HSPD-12 alone requires.

The Forms and How to File

The questionnaire you fill out depends on risk level. Non-sensitive, low-risk positions use Standard Form 85 (SF-85).⁵ Moderate-risk public trust positions use SF-85P, which adds questions about financial history and foreign contacts. Both forms were revised in February 2024, and the updated versions are the only ones DCSA accepts as of August 2025.⁶

Both forms ask for residential history, employment history, education, references, and information about foreign contacts and travel. Plan to account for at least the past five years across most categories. Be thorough, and be honest. An incomplete answer will slow your investigation. An intentionally false one is itself a disqualifying suitability factor under 5 CFR 731.202.⁷

You will not submit anything on paper. All background investigation questionnaires now go through NBIS eApp, which became the sole system for case initiation after every federal agency completed its transition in late 2024.⁸ Your sponsoring agency initiates the case and sends you login credentials. The system walks you through the questionnaire section by section, and you can save your progress. Have addresses, employer contact details, and reference information ready before you start; pulling from a prepared list beats reconstructing five years of history from memory inside the portal.

What Happens After You Submit

Once your questionnaire is in, two things happen roughly in parallel: fingerprinting and the DCSA investigation.

Fingerprints and the FBI Check

Your sponsoring agency schedules you for digital fingerprinting, either at a federal facility or through an approved vendor. Prints go to the FBI for a National Criminal History Check. A favorable FBI fingerprint result is a prerequisite for even an interim PIV card.⁴

Investigation

DCSA investigators verify what you provided by contacting your references, current and former employers, educational institutions, and local law enforcement in places where you have lived. Tier 2 adds a credit check and possibly a personal interview.

Adjudication

A trained adjudicator then reviews the findings against the suitability factors in 5 CFR 731.202. The question the adjudicator answers is whether you pose an acceptable risk for the position, not whether your record is spotless. A favorable adjudication clears you for PIV card issuance and the access your role requires.⁹

What Adjudicators Are Actually Judging

Nine factors listed in 5 CFR 731.202 are the only grounds for an unsuitability finding:

Criminal conduct, including arrests, charges, and convictions, and in some cases expunged records
Dishonest conduct, such as fraud, theft, or a pattern of deception
False statements or material omissions on your application
Misconduct or negligence in prior employment, including firings for cause and repeated discipline
Illegal drug use without evidence of rehabilitation
Excessive alcohol use, without evidence of rehabilitation, when it suggests you could not safely perform your duties
Violent conduct
Acts aimed at overthrowing the U.S. government by force
Any statutory bar that legally prohibits your employment in the specific position

Adjudicators weigh these against mitigating circumstances: how long ago the conduct occurred, how serious it was, whether it’s likely to recur, and how old you were at the time.⁷ A decade-old misdemeanor with no repeat offenses reads very differently from a recent pattern of dishonesty. The phrase “without evidence of rehabilitation” attached to the drug and alcohol factors is the tell: the government is looking at trajectory, not just history.

False statements catch more applicants than criminal history does. People try to hide a minor issue and turn it into a major one. If something is going to surface in the investigation, disclose it on the form.

Getting an Interim PIV Card While You Wait

Full investigations take time. To keep new employees from being locked out for weeks or months, agencies can issue an interim PIV card once four conditions are all met:

You presented two identity documents, at least one a government-issued photo ID
The agency reviewed your completed questionnaire and found no red flags
Your background investigation request has been submitted and scheduled with DCSA
Your FBI fingerprint check came back favorable

When all four are in place, the agency can make a favorable interim determination and issue the card while the full investigation continues.⁴ Functionally, the interim card works the same as a final PIV for physical and logical access. If disqualifying information surfaces later, the interim determination is revoked and the card is pulled.

If You Get an Unfavorable Determination

If the adjudicator decides you are unsuitable, you receive a written notice of proposed action. It lays out the specific charges and the reasons behind them. You have the right to review the materials the agency relied on and to designate a representative.¹⁰

You get 30 days from the date of the notice to submit a written response. That response can include documentation, affidavits, and evidence of mitigating circumstances such as rehabilitation, changed behavior, or context the investigation missed. The agency then issues a final written decision. If that decision is still unfavorable, you can appeal to the Merit Systems Protection Board (MSPB) under 5 CFR Part 731, Subpart E.¹⁰

The strongest responses don’t simply deny the charges. They acknowledge accurate facts and present concrete evidence that the concern no longer applies: completed treatment programs, years of clean employment, character references from supervisors who know the full picture.

After You’re Cleared: Continuous Vetting and Renewals

Passing the initial check is not the end. The federal government has been replacing periodic reinvestigations with continuous vetting, an automated system that monitors certain records on an ongoing basis instead of waiting for a scheduled five-year reinvestigation. OPM directed agencies to begin enrolling non-sensitive public trust employees in continuous vetting starting in fiscal year 2024.¹¹

In practice, a new arrest, a serious financial problem, or another relevant change in your circumstances can be flagged automatically rather than sitting undetected until your next reinvestigation. A flag doesn’t automatically mean loss of access. The same suitability factors and mitigating-circumstances analysis apply to continuous vetting alerts that apply to initial adjudications.⁷

The PIV card itself has its own timers. Under FIPS 201 and HSPD-12, the physical card must be replaced every five years. The embedded digital certificates must be updated every three years, and your agency’s security office will notify you when that renewal is due.¹²

1
Department of Homeland Security. Homeland Security Presidential Directive 12 – Policy for a Common Identification Standard for Federal Employees and Contractors
2
U.S. Office of Personnel Management. Final Credentialing Standards for Issuing Personal Identity Verification Cards under HSPD-12
3
U.S. Office of Personnel Management. Credentialing Standards Procedures for Issuing Personnel Identity Verification Cards under HSPD-12
4
U.S. Office of Personnel Management. Credentialing Standards Procedures for Issuing Personal Identity Verification Cards under HSPD-12
5
U.S. Office of Personnel Management. Standard Form 85 – Questionnaire for Non-Sensitive Positions
6
Defense Counterintelligence and Security Agency. Deadline Approaching for Use of February 2024 Version of Standard Forms
7
eCFR. 5 CFR 731.202 – Criteria for Making Suitability Determinations
8
Defense Counterintelligence and Security Agency. DCSA Announces Full Transition to NBIS eApp for Background Investigation Initiation
9
Legal Information Institute. 5 CFR Part 731 – Suitability and Fitness
10
eCFR. 5 CFR Part 731 Subpart C – OPM Suitability Action Procedures
11
U.S. Office of Personnel Management. Continuous Vetting for Non-Sensitive Public Trust Positions
12
IBC Customer Central. PIV Card Renewal – PIV Card Expiration