Changes to the Security Clearance Mental Health Question

Over the past few decades the mental health question on the most commonly used national security clearance application form has become increasingly complex as the form itself has grown incredibly long and detailed.

The 1964 version of DOD Form 398 (DD398), “Statement of Personal History,” was only 4 pages long and contained no question regarding mental health or mental health treatment.

In 1981 the DD398 was renamed the “Personnel Security Questionnaire,” was reduced from 4 pages to 3 pages, and the following mental health question was added:

Have you ever been a patient (whether or not formally committed) in any institution primarily devoted to the treatment of mental, emotional, psychological, or personality disorders?

In 1990 the DD398 went back to being 4 pages, and the mental health question was revised to read:

Have you ever been treated for a mental, emotional, psychological, or personality disorder/condition/problem?

Have you ever consulted or been counseled by any mental health professional?

Several years later DOD stopped using the DD398 and began using the 1995 version of the Standard Form 86 (SF86), “Questionnaire For National Security Positions,” in a computer-based form known as the “Electronic Personnel Security Questionnaire” (EPSQ). The paper version of the 1995 SF86 was 9 pages long and contained the following regarding mental health at Question 21:

In the last 7 years, have you consulted with a mental health professional (psychiatrist, psychologist, counselor, etc.) or have you consulted with another health care provider about a mental health related condition?

If you answered “Yes,” provide an entry for each treatment to report, unless the consultation(s) involved only marital, family, or grief counseling, not related to violence by you.

In 2004 DOD discontinued the EPSQ and started using the Office of Personnel Management’s (OPM) computer-based version of the SF86—the Electronic Questionnaires for Investigations Processing (e-QIP).

In July 2008 a new 17-page version of the SF86 was issued, and Question 21 was changed to read:

Mental health counseling in and of itself is not a reason to revoke or deny a clearance.

In the last 7 years, have you consulted with a health care professional regarding an emotional or mental health condition or were you hospitalized for such a condition? Answer “No” if the counseling was for any of the following reasons and was not court-ordered:
1) strictly marital, family, grief not related to violence by you; or
2) strictly related to adjustments from service in a military combat environment.

Like the previous version of the SF86, each period of treatment had to be listed separately and required dates and contact information for the medical practitioner.

In December 2010 another revision to the SF86 was approved, which increased the number of pages in the print version from 17 to 121. The mental health question was expanded to include questions about inpatient treatment, declarations by a court or administrative agency regarding mental incompetence, and subsequent appeals.

Many federal agencies had been routinely “declining” to grant interim security clearances to applicants who listed any mental health treatment on their SF86, because they did not consider an interim clearance declination to be a clearance denial. In September 2012 the Secretary of Defense issued a memorandum regarding Question 21 of the SF86. The memo clearly stated that “mental health counseling alone cannot form the basis of a denial of an interim security clearance. . . .” This eliminated the biggest problem confronting applicants who were receiving or had received counseling.

In March 2013 OPM posted a 60 day notice and request for comments for proposed changes to the SF86 that would completely change Question 21. Included in the proposed change is a 189-word explanation of the government’s policy regarding mental health treatment. The proposed change to the question itself reads:

In the last seven (7) years, have you had a mental health condition that would cause an objective observer to have concern about your judgment, reliability, or trustworthiness in relation to your work? Evidence of such a condition could include exhibiting behavior that was emotionally unstable, irresponsible, dysfunctional, violent, paranoid, or bizarre; receiving an opinion by a duly qualified mental health professional that you had a condition that might impair judgment, reliability, or trustworthiness; or failing to follow treatment advice related to a diagnosed emotional, mental, or personality condition (e.g., failure to take prescribed medication). These examples are merely illustrative. Merely consulting a mental health professional is not, standing alone, evidence of such a condition. [Emphasis added]

A “Yes” or “I don’t know” response to the question requires detailed information regarding any treatment. The questions regarding inpatient treatment and declaration by a court or administrative agency regarding mental incompetence remain the same.

Because changes to the SF86 can take a year or more to implement, the Director of National Intelligence (DNI) and OPM issued an interim change to the instructions for Question 21 in April 2013 to create an immediate exception for victims of sexual assault. The interim change adds the following instruction to the current version of Question 21:

Please respond to this question with the following additional instruction: Victims of sexual assault who have consulted with a health care professional, regarding an emotional or mental health condition during this period strictly in relation to the sexual assault are instructed to answer “No.”

Since 1981 when the mental health question was first included in a security clearance application form, the question has been expanded and later qualified in an effort to request from the applicant only information relevant to a security clearance determination and to remove perceived disincentives to seeking certain types of treatment. Despite statements to the contrary in Executive Order 12968, the Adjudicative Guidelines, and the SF86 itself, people still reportedly avoid seeking treatment, because they believe that any treatment will adversely affect their eligibility for a security clearance. The two most recent changes to Question 21—exceptions for combat-related post-traumatic stress disorder and sexual assault counseling—were created to encourage more people to obtain counseling when needed. But creating exceptions to Question 21 is not the solution.

The proposed change to the SF86 removes the exceptions and aligns Question 21 more closely to the “Psychological Conditions” criterion (Guideline I) of the Adjudicative Guidelines. However, the proposed change uses wording that requires a subjective rather than an objective response, thereby facilitating self-serving answers. It’s questionable whether the proposed change will actually result in applicants providing useful information. It’s also questionable whether a person with a mental condition that affects their judgment has an accurate perception of their own condition. It’s even more questionable whether they can accurately perceive how an “objective observer” might view their condition.

Perhaps the time has come to eliminate the mental health question completely or at least temporarily until it can be properly studied by the Defense Personnel Security Research Center. The DD398 existed for decades without a mental health question. A July 2009 article at www.Army.mil reported that the US Army Central Clearance Facility’s (CCF) “adjudicative history indicates that 99.98 percent of cases with psychological concerns obtained/retained their security clearance eligibility.

The SF86 does not ask questions about every potentially disqualifying factor listed in the Adjudicative Guidelines, such as security violations, susceptibility to blackmail, association with criminals, and undetected criminal conduct. There appears to be little justification for a mental health question considering the very few cases where clearances are actually denied or revoked due to this issue. It’s worth noting that neither the SF85 (Questionnaire For Non-Sensitive Positions) nor the SF85P (Questionnaire for Public Trust Positions) have questions regarding mental health or mental health treatment.

Serious mental health conditions, not controlled by treatment, often surface in security clearance investigations due to conduct covered under other criteria in the Adjudicative Guidelines, such as criminal arrests, employment rule violations, financial delinquencies, drug and alcohol abuse, inappropriate behavior in the workplace, etc. The field portion of a Single Scope Background Investigation (SSBI) conducted for Top Secret clearances should have no difficulty identifying the existence of a serious mental health condition. However, the National Agency Check with Law and Credit (NACLC) conducted for most Secret clearances is not well suited for surfacing problems other than criminal conduct and financial delinquencies. The Access National Agency Check with Inquiries (ANACI) is far better than the NACLC at surfacing secondary indicators of serious mental health problems and only costs $32 more than the NACLC ($260 versus $228). Concerns over eliminating the mental health question on the SF86 could be adequately mitigated by minor changes to initial and periodic clearance investigations.


by William Henderson
Copyright © 2013 Federal Clearance Assistance Service. All rights reserved.

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