A moderate risk public trust clearance is a federal suitability determination — technically a Tier 2 background investigation — that qualifies you for a position handling sensitive but unclassified information. It is not a security clearance. The government uses the SF-85P questionnaire to gather your history, then decides whether you’re trustworthy enough to hold a role where misuse of access could cause a fair amount of harm to government operations or public confidence.1National Institutes of Health Office of Management. Understanding U.S. Government Background Investigations and Reinvestigations People often call it an “MRPT clearance,” but the label matters: the legal framework and your appeal rights differ from what applies to classified access.
How It Differs From a Security Clearance
Confidential, Secret, and Top Secret clearances grant access to classified national security information and use the SF-86. A moderate risk public trust determination grants access to sensitive but unclassified information and uses the SF-85P. The investigation is narrower in scope, there is no polygraph, and candidates are evaluated under the suitability standards set by the Office of Personnel Management rather than the national security adjudicative guidelines that govern classified access.1National Institutes of Health Office of Management. Understanding U.S. Government Background Investigations and Reinvestigations
If a job posting says “public trust” instead of “Secret” or “Top Secret,” you’re in suitability territory. The background check still reaches into your history, but the framework is different from the classified world in ways that matter later, especially if things go wrong.
What “Moderate Risk” Covers
Every federal position is designated low, moderate, or high risk based on the potential damage the employee could do. A moderate designation applies when the position could produce a “fair amount of harm or serious damage to the public’s trust” through misused access or authority.2Office of Personnel Management. Position Designation Tool
The information at stake includes personally identifiable information, financial records, law enforcement sensitive data, and proprietary business information — anything that needs protection but isn’t classified.3US EPA. Controlled Unclassified Information (CUI) Program Frequently Asked Questions (FAQs) Typical roles include policy assistants, data analysts working with government records, mid-level program managers, IT support staff with access to federal systems, and administrative personnel who handle sensitive personal or financial data.
Both federal civilian employees and government contractors can be subject to a Tier 2 investigation.4Federal Register. Submission for Review: Questionnaire for Public Trust Positions (SF 85P) and Supplemental Questionnaire for Selected Positions (SF 85P-S) You cannot request one on your own. The sponsoring agency determines whether your position requires one, and the investigation starts only after you receive a conditional job offer.5United States Department of State. Security Clearances
What the SF-85P Asks For
The Standard Form 85P is the core document. It asks for a detailed personal history, and incomplete or dishonest answers are one of the fastest ways to get denied. Expect to disclose:
- Residential history, typically covering the past seven to ten years
- Every job held during the covered period, including reasons for leaving
- Schools attended and degrees earned
- Financial history, including delinquent debts, unpaid taxes, bankruptcies, and court judgments
- Foreign contacts that go beyond casual or purely professional interaction
- Arrests, charges, and convictions
- Any illegal drug use, including marijuana, which remains federally illegal regardless of state law
Debt alone doesn’t disqualify you. Hidden debt does, because concealment raises questions about honesty and vulnerability to pressure. Male applicants born after December 31, 1959, must document Selective Service registration; anyone 26 or older who never registered must show OPM that the failure wasn’t knowing or willful, or they’re ineligible for federal employment entirely.6eCFR. 5 CFR 300.704 – Considering Individuals for Appointment
The submission platform has changed. The old eQIP system was retired on October 1, 2023, and applications now go through the NBIS eApp, operated by the Defense Counterintelligence and Security Agency.7DCSA. Federal Investigations Notice No. 23-02 – Transition to NBIS eApp The government also plans to eventually replace the SF-85P with a new Personnel Vetting Questionnaire under the Trusted Workforce 2.0 reform.8Federal Register. Notice of Submission for a New Information Collection Common Form Personnel Vetting Questionnaire Your sponsoring agency will tell you which form to complete.
How the Investigation Runs
Once you accept a conditional offer, a clearance coordinator walks you through the SF-85P and collects your fingerprints.5United States Department of State. Security Clearances Investigators then verify what you provided against commercial and government databases, pull your credit report, and check law enforcement records. They may interview you and contact former employers, neighbors, and references to corroborate your history.
Timelines vary widely. The State Department notes that investigations can occasionally wrap up in as little as two months, but most take longer depending on the complexity of your background and the agency’s workload.5United States Department of State. Security Clearances Extensive foreign travel, many past addresses, or unresolvable discrepancies in your records will slow things down.
Because investigations take time, agencies can issue an interim (preliminary) determination that lets you start working before the final decision. Interim determinations are usually based on clean initial fingerprint and credit checks, and they can be withdrawn at any point if new information surfaces.5United States Department of State. Security Clearances
What Investigators Weigh
Public trust candidates are evaluated under the suitability factors set out in 5 CFR 731.202, not the 13 adjudicative guidelines used for security clearances. Those factors include misconduct or negligence in employment; criminal or dishonest conduct; intentional false statements or fraud during the application process; excessive alcohol use without evidence of rehabilitation, to a degree suggesting you couldn’t safely perform the job; illegal drug use without evidence of rehabilitation; acts designed to overthrow the U.S. government by force; statutory or regulatory bars to the specific position; and violent conduct.9eCFR. 5 CFR 731.202 – Criteria for Making Suitability and Fitness Determinations
None of these is automatically disqualifying. Investigators weigh the nature and seriousness of the conduct, how recently it happened, your age at the time, and whether you’ve demonstrated rehabilitation. A DUI from a decade ago that you disclosed upfront reads very differently from one you tried to hide last year. Honesty on the form matters as much as the underlying facts. Imperfect histories are expected. Deception is not tolerated.
A Word on Marijuana
Marijuana catches people off guard more than any other item. Even if your use was legal under state law, it remains a federal controlled substance, and the SF-85P asks about it. A pattern of recent use is harder to mitigate than isolated past use. Never lie about it. A false statement on the form is independently disqualifying and much harder to overcome than the drug use itself.
If You’re Denied
When the investigation concludes, the hiring authority tells you the outcome. An unfavorable determination comes with the reasons and information about your options.5United States Department of State. Security Clearances
Your appeal rights depend heavily on whether you’re a federal employee or a contractor. Federal employees in the competitive service can appeal suitability determinations to OPM and ultimately to the Merit Systems Protection Board. Contractor employees have much weaker protections. There is no government-wide rule guaranteeing contractors the right to appeal an adverse public trust determination. Some agencies, including the State Department, have internal policies that give contractors a limited opportunity to submit a written response and request higher-level review, but this varies by agency. If you’re a contractor facing a denial, your first move should be finding out exactly what procedural rights your agency provides.
How Long It Lasts
A moderate risk public trust determination doesn’t last forever. Historically, individuals in public trust positions were subject to reinvestigation at least once every five years.10eCFR. 5 CFR 1400.203 – Periodic Reinvestigation Requirements That model is being replaced.
The Defense Counterintelligence and Security Agency began enrolling the non-sensitive public trust workforce in Continuous Vetting in August 2024.11Defense Counterintelligence and Security Agency. Continuous Vetting Enrollment Begins for Non-sensitive Public Trust Federal Workforce Under continuous vetting, the government monitors automated records on an ongoing basis rather than waiting five years to reinvestigate from scratch. Full enrollment of the public trust workforce was targeted for October 2025, with more advanced capabilities rolling out through fiscal year 2026.12Performance.gov. Trusted Workforce 2.0 Quarterly Progress Report For employees, the practical upside is smoother transfers between federal positions at the same or lower level of trust.
Moving Between Agencies
If you already hold a favorable suitability or fitness determination from one federal agency, a new agency is generally expected to recognize it rather than starting a new investigation from zero. Executive Order 13488 establishes this reciprocity, provided the new agency uses equivalent suitability standards, the prior determination was based on equivalent standards, and you haven’t had a break in employment since it was granted.13GovInfo. Executive Order 13488 – Granting Reciprocity on Excepted Service and Contractor Employees
Reciprocity has limits. The new agency does not have to honor a prior determination if the new position requires a higher level of investigation, if new derogatory information has surfaced, or if your record shows conduct incompatible with the new role’s duties.13GovInfo. Executive Order 13488 – Granting Reciprocity on Excepted Service and Contractor Employees Lateral moves usually go smoothly. If you’re moving from a moderate risk role to a high risk public trust position or into classified work, expect additional investigation regardless of what you already hold.