What Is a Tier 1 Investigation? SF-85, Checks, and Disqualifiers

A Tier 1 background investigation is the federal government’s least intensive background check, used to vet people for non-sensitive, low-risk positions and to credential federal employees and contractors who need a PIV card or building access. It doesn’t involve classified information, and it doesn’t involve investigators knocking on your neighbor’s door. It’s built on a questionnaire you fill out, the SF-85, and a set of automated records checks run against what you reported.¹

Tier 1 sits at the bottom of a five-tier federal system. Higher tiers add real investigative work: interviews with references, neighbors, and former coworkers, and, at Tier 5, a decade-long look back for Top Secret access. Tier 1 has none of that. If your position involves classified information or public trust responsibilities, you’re not on the Tier 1 track.

When You’ll Encounter One

Most people run into a Tier 1 for one of two reasons. Either they’re being hired into a non-sensitive federal position, or they need a Personal Identity Verification (PIV) card — the smart card federal employees and many contractors use to enter buildings and log into government networks. A completed Tier 1 is the minimum required for a final PIV credential eligibility determination.²

Non-U.S. nationals face an extra rule. If you’ve lived continuously in the United States for three or more years, the agency can initiate a standard Tier 1 for you. With fewer than three years of continuous U.S. residence, a Tier 1 can’t be requested, and the agency may instead issue an alternative facility access card based on its own risk assessment.²

The SF-85 Questionnaire

The process starts when your sponsoring agency sends you Standard Form 85, “Questionnaire for Non-Sensitive Positions.” You submit it electronically through the government’s eApp system.³

The SF-85 covers roughly the last five years of your life. You’ll report:

Where you’ve lived, with someone who can verify each address within the last three years
Jobs held and any periods of unemployment
Schools attended, with a verifying contact for each
Any illegal use of controlled substances
Citizenship and passport information, including dual citizenship

The form also collects your Social Security number, date of birth, and the identifying details needed to run records checks.⁴

Double-check dates, addresses, and contact information before you submit. Incomplete or inconsistent forms get kicked back for correction, and that’s one of the most common sources of delay.

What Investigators Actually Check

A Tier 1 is primarily a records review, run by the Defense Counterintelligence and Security Agency (DCSA). No one interviews the people you listed. Instead, your information runs through a series of databases.

The core checks include a national agency check with FBI fingerprint records, which can surface criminal history well beyond the five-year window. Investigators pull your credit report to look for patterns of financial trouble: delinquent accounts, defaults, collections, or a mismatch between your income and your spending. That pull is a soft inquiry, so it doesn’t affect your credit score.

Local law enforcement checks catch arrests and interactions that might not appear in federal databases. Your employment and education entries on the SF-85 are verified against outside records. The focus is roughly the last five years, though fingerprint and certain criminal history databases reach further back.

How the Process Moves

After you submit the SF-85, your sponsoring agency reviews it for completeness and accuracy. Once it’s accepted, the records-check phase begins. Because the work is automated, this portion moves faster than higher-tier investigations. When the checks are complete, the report goes to your sponsoring agency, which makes the final suitability or fitness determination.⁵

You often don’t have to wait for the full investigation to close before starting work. The sponsoring agency can grant interim eligibility at its discretion while the investigation is still in progress, provided the early portions — typically the fingerprint check and initial record queries — come back favorable. Interim PIV determinations work the same way: an agency can make one once your Tier 1 has been submitted and scheduled.⁵

What Can Disqualify You

The 13 national security adjudicative guidelines don’t apply here; those are for security clearances at Tier 3 and above. For Tier 1 positions, suitability is judged against factors set out in federal regulation. An agency can find you unsuitable based on:

Criminal or dishonest conduct, including fraud, theft, or a pattern of deception. Formal charges aren’t required.
False statements or material omissions on the SF-85. Only OPM, not individual agencies, can take action on this specific factor.
Misconduct or negligence in past employment, such as being fired for cause.
Illegal drug use without evidence of rehabilitation.
Excessive alcohol use without rehabilitation, when it would prevent you from performing the job or endanger others.
Violent conduct.
Acts designed to overthrow the U.S. government by force.
A statutory bar to employment for the role in question.

None of these trigger automatic disqualification. The adjudicator weighs the seriousness of the conduct, how recent it was, and whether there’s evidence of rehabilitation.⁶

Marijuana and Other Drug Use

Federal law still classifies marijuana as illegal regardless of state law, and federal employees must refrain from using it. But OPM guidance is clear that agencies cannot automatically find someone unsuitable based on past marijuana use. Past use, even recently discontinued, is treated differently from ongoing use, and a credible commitment to stop can count as evidence of rehabilitation.⁷

Financial Problems

Serious financial issues on your credit report raise concerns: delinquencies, defaults, bankruptcies, wage garnishments, and unexplained wealth inconsistent with your known income. Default on federal student loans has been treated as an automatic disqualifier at certain agencies. The main mitigating factor is whether you can explain the difficulty and show you’re addressing it. A medical bankruptcy tells a different story than a pattern of reckless spending.

Lying on the SF-85

The form warns you: providing false information is a federal crime. Under 18 USC 1001, knowingly making a materially false statement in a matter within government jurisdiction is punishable by up to five years in prison.⁸

The more immediate consequence is that dishonesty is itself a suitability factor, and adjudicators take it seriously. An arrest from years ago that you disclosed honestly is a problem you can mitigate with context. That same arrest, concealed and later discovered, becomes a dishonesty problem on top of a criminal conduct problem. Investigators expect imperfect histories. What they don’t tolerate is deception about them.

If You’re Denied

You have appeal rights. When OPM or an agency takes a suitability action against you, you can appeal to the Merit Systems Protection Board (MSPB).⁹

You file with the MSPB regional or field office that has jurisdiction over your location. An administrative judge reviews the case and issues an initial decision. If neither side files a petition for review within 35 days, that initial decision becomes final. Either party can petition the full Board in Washington to review it, and the Board’s ruling on that petition is the final administrative action.¹⁰

The Board applies a preponderance-of-the-evidence standard. If it finds even one of the charges against you is supported, it affirms the suitability determination. If it sustains only some charges, the case goes back to the agency to decide whether the original action was proportionate to the charges that held up. Winning on some charges doesn’t automatically reverse the denial, but it can change the outcome.

Continuous Vetting After a Favorable Result

A favorable Tier 1 determination isn’t the end of the story. Under the Trusted Workforce 2.0 framework, the government is moving from periodic reinvestigations to continuous vetting: ongoing automated monitoring of certain records. The national security workforce has already been fully enrolled, and enrollment of the non-sensitive public trust population has been underway with a target completion around the end of fiscal year 2025.¹¹

For moderate- and high-risk public trust positions, continuous vetting replaces periodic reinvestigations entirely. For low-risk Tier 1 positions, the scope may be narrower, but the direction is the same.¹²

The practical takeaway: an issue that arises after your initial investigation, whether a DUI, a debt default, or a drug arrest, may be flagged in near-real time and prompt a review of your continued suitability rather than sitting undisturbed until some future reinvestigation.

1
National Institutes of Health Office of Management. Understanding U.S. Government Background Investigations and Reinvestigations
2
U.S. Office of Personnel Management. Credentialing Standards Procedures for Issuing Personal Identity Verification Cards under HSPD-12
3
Defense Counterintelligence and Security Agency. Electronic Questionnaires for Investigations Processing (e-QIP)
4
U.S. Office of Personnel Management. Questionnaire for Non-Sensitive Positions, SF 85
5
Defense Counterintelligence and Security Agency. Investigations and Clearance Process
6
eCFR. 5 CFR Part 731 Subpart B – Criteria for Making Suitability and Fitness Determinations
7
OPM. Assessing the Suitability/Fitness of Applicants or Appointees on the Basis of Marijuana Use
8
Office of the Law Revision Counsel. 18 USC 1001 – Statements or Entries Generally
9
eCFR. 5 CFR 731.501 – Appeal to the Merit Systems Protection Board
10
U.S. Merit Systems Protection Board. Jurisdiction
11
Performance.gov. Trusted Workforce 2.0 Transition Report
12
U.S. Office of Personnel Management. Continuous Vetting for Non-Sensitive Public Trust Positions Overview and FAQs