OPM Position Designation System: Ratings, Tiers, and Assignment

The OPM Position Designation System is the federal government’s standardized method for rating every federal job on two separate scales before anyone is hired into it: a national security sensitivity level and a public trust risk level. Those two ratings, assigned to the position rather than to the person, decide which background investigation tier the government will run, which standard form the applicant fills out, and how closely the role is monitored afterward. The system is run jointly by the Office of Personnel Management and the Defense Counterintelligence and Security Agency.¹

The point of running two scales in parallel is that federal jobs can be sensitive in two very different ways. A role might touch classified information, or it might control money, systems, or public safety without ever seeing a classified document. The designation captures both.

The Two Ratings Every Position Receives

National security sensitivity, governed by 5 CFR Part 732, measures the damage someone in the role could do to national security.² Public trust risk, governed by 5 CFR Part 731, measures the damage someone could do to the integrity of government operations, public safety, or public funds.³ Every position gets a rating on each scale. A job can be Non-Sensitive on the national security side and High Risk on the public trust side, or Critical-Sensitive on one and Low Risk on the other. The combined result is what drives the investigation.

National Security Sensitivity: Four Levels

At the bottom sits Non-Sensitive, meaning routine work with no access to classified information or restricted facilities. Above that are three tiers of sensitivity:

Noncritical-Sensitive covers positions with access to Confidential or Secret information, where an unauthorized disclosure could cause serious but not catastrophic damage. This is the most common sensitivity designation for cleared federal workers.
Critical-Sensitive covers roles with Top Secret access, significant policy authority, or duties that could cause exceptionally grave damage to national security.
Special-Sensitive is the highest tier, covering access to Sensitive Compartmented Information, counterintelligence work, and Special Access Programs.

The regulation itself defers to OPM guidance for the exact investigative requirements attached to each level.⁴

Public Trust Risk: Three Levels

Public trust risk is assigned as Low, Moderate, or High based on the potential harm from misconduct in the role.

Low Risk positions have limited potential to damage the agency’s mission. Most administrative and clerical work sits here.
Moderate Risk positions involve fiduciary responsibilities, access to sensitive personal records, or duties where poor judgment could cause meaningful financial loss or mismanagement.
High Risk positions include high-level policy roles, law enforcement, and jobs with major financial oversight.

Any position rated Moderate or High is formally classified as a “public trust” position, a label that carries its own procedural weight in later vetting.³

The Money Thresholds That Push a Position Up or Down

Fiscal responsibility is the most concrete input on the public trust side. OPM’s Position Designation System document sets specific dollar cutoffs:⁵

Automatic High Risk when the role controls, spends, or procures more than $50 million annually, or disburses $10 million or more per year from government computer systems.
High Risk (Severe Impact) when the role controls or procures between $10 million and $50 million annually.
Moderate Risk when the role controls or procures between $2 million and $10 million annually, or between $1 million and $2 million if effective oversight is limited.
Low Risk when the role controls or procures less than $2 million annually with meaningful controls in place to detect abuse.

Money is not the only factor. The system also weighs access to government IT systems, involvement in public safety, and the degree of independent judgment the role demands. But fiscal responsibility is where the clearest line between risk levels usually gets drawn.

How the Two Ratings Combine Into an Investigation Tier

Once a position has both a sensitivity level and a risk level, those ratings map to one of five investigation tiers. Each tier has its own standard form:⁶

Tier 1 (SF-85) for Low Risk, Non-Sensitive positions. The shortest form: basic identity, employment, and residence history.
Tier 2 (SF-85P) for Moderate Risk public trust positions. Adds financial records and more detailed personal history.
Tier 3 (SF-86) for Noncritical-Sensitive positions at Moderate Risk. The SF-86 is the most detailed questionnaire, covering foreign contacts, financial history, drug use, and mental health treatment.
Tier 4 (SF-85P) for High Risk public trust positions that are Non-Sensitive.
Tier 5 (SF-86) for Critical-Sensitive, Special-Sensitive, and High Risk national security positions. Same form as Tier 3, but the investigation goes much further, including personal interviews with references, coworkers, and neighbors.⁷

Two facts about this mapping are worth pinning down. First, the same form (SF-86) covers both Tier 3 and Tier 5, so the questionnaire you fill out does not, by itself, tell you how deep the investigation will go. Second, the SF-85P is used for both Tier 2 and Tier 4, so a public trust designation covers a wide range of scrutiny depending on whether the risk was rated Moderate or High.

Who Assigns the Rating, and How

Designations are made by the hiring agency, typically by an HR specialist or security officer working from the position description. To keep the process consistent across agencies, OPM and DCSA provide the Position Designation Automated Tool, a web-based application meant to remove subjectivity from the decision.¹ The stated goal is that two identical jobs at different agencies should produce identical vetting requirements.

Before using the tool, the person doing the designation needs the position’s formal description, the primary duties, the level of supervision the employee will receive, the role’s fiscal responsibility, the extent of IT system access, and the degree of independent decision-making involved. The tool then walks through structured prompts on the nature of the work, the potential for public harm, and access to government networks and classified systems. It outputs both a sensitivity level and a risk level, which together identify the investigation tier. That output is recorded directly on the position description and becomes the basis for everything that follows.

Vague inputs produce inaccurate designations. The financial thresholds above are the kind of detail the tool asks for specifically, and rough estimates at that stage carry through to the rest of the vetting process.

What the Designation Does Not Decide

The designation determines which investigation runs. It does not decide whether the person who fills the position will pass that investigation. Those judgments live in separate frameworks: national security adjudications apply the 13 guidelines in Security Executive Agent Directive 4 under a “whole-person” analysis,⁸ and public trust suitability applies the factors in 5 CFR 731.202, which include misconduct in prior employment, criminal conduct, dishonesty in the hiring process, and several others.⁹

The designation also does not decide whether you need a fresh investigation if you already have a clearance. Reciprocity under Security Executive Agent Directive 7 generally requires a receiving agency to accept an existing investigation for a position at the same or lower sensitivity level, as long as the prior investigation is no more than seven years old and no new derogatory information has surfaced.¹⁰ And once you are cleared, ongoing scrutiny happens through continuous vetting under Trusted Workforce 2.0, which runs automated checks of public and government records rather than waiting for a periodic reinvestigation.¹¹

In short, the Position Designation System sits at the front of the process. It tells the agency, before a candidate is even identified, how thoroughly the role must be vetted. Everything downstream — the form, the tier, the depth of the field work, the reporting obligations that come with the position later — flows from the two ratings assigned at this first step.

1
U.S. Office of Personnel Management. Position Designation Tool
2
eCFR. 5 CFR Part 732 – National Security Positions
3
eCFR. 5 CFR 731.106 – Designation of Public Trust Positions and Investigative Requirements
4
eCFR. 5 CFR 732.201 – Sensitivity Level Designations and Investigative Requirements
5
Office of Personnel Management. Position Designation System
6
Defense Counterintelligence and Security Agency. Position Designation Investigation Type Chart
7
Defense Counterintelligence and Security Agency. Case Types and Forms
8
Office of the Director of National Intelligence. Security Executive Agent Directive 4 – National Security Adjudicative Guidelines
9
eCFR. 5 CFR 731.202 – Criteria for Making Suitability Determinations
10
Office of the Director of National Intelligence. Security Executive Agent Directive 7 – Reciprocity of Background Investigations and National Security Eligibility Determinations
11
Center for Development of Security Excellence. Continuous Vetting Trifold