The Revisions Made to the Psychological and Emotional Health Questions on the Standard Form 86, Questionnaire for National Security Positions.

In a November 16, 2016-dated memorandum ES-2016-00751, James R. Clapper, the retiring Director of National Intelligence, made revisions to the psychological and emotional health questions on the Standard Form 86, questionnaire for national security positions. .

In my experience, mental health counseling alone rarely disqualified an individual from obtaining a clearance.  Not disclosing such treatment, however, can disqualify an individual from obtaining a clearance.  These changes may encourage some to seek psychiatric care or counseling when needed, which was a purpose of the revisions.

But also, the concerns I hear from clients and applicants for a security clearance are what does he or she need to disclose under adjudicative Guideline I (psychological conditions), if anything, and/or concerns under Guideline E (personal conduct) when asked about possible omission of material information or events. The changes to SF-86 question 21 are relevant to these concerns, albeit not addressing all of them.

More specifically, the revised version of question 21 no longer asks about the “fact” of mental health treatment. It asks whether the applicant has:

a) been declared mentally incompetent by a court or administrative agency
b) been ordered to consult with a mental health professional by a court or administrative agency
c) been hospitalized for a mental health condition
d) been diagnosed by a physician or other health professional with specifically listed diagnoses; and/or
e) a mental health or other health condition that substantially adversely affects judgment, reliability and trustworthiness.

These revisions clarify some issues on how to answer question 21, and clarifying training and guidance will follow the Clapper Memo. “The National Background Investigations Bureau, in concert with DoD, is currently establishing the technical implementation of S21 revisions into the Electronic Questionnaire for Investigative Processing (eQIP_ system.” Clapper Memo.

The revisions are welcome.  My mantra remains: Each case is different. Each person is different.  Let me know if you need assistance during the security clearance adjudicative process.  Early assistance avoids later problems.

That being said, I hope that you do not need my services for anything seriously impacting your life or career, and thus wish each of you a happy 2017.

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