Applying for a federal job comes with a background check step that most private sector hiring does not have. Instead of a single consumer report pulled by a screening company, the federal government sorts every position into a risk and sensitivity category first, and that category decides which questionnaire an applicant fills out, how deep the investigation goes, and which agency reviews the results. The three forms that show up most often are the SF 85, the SF 85P, and the SF 86. They look similar on the surface, since all three ask for residence, employment, education, and reference information, but they exist for different reasons and trigger different levels of scrutiny. This guide explains how position designation works, what each form covers, who actually conducts the investigation today, and how this process is different from a standard employment background check governed by the Fair Credit Reporting Act.
Position sensitivity and risk come before the form
The starting point is not the applicant, it is the position. Federal regulations require every agency to evaluate each covered position and assign it a designation before anyone is hired into it. Part 731 of Title 5 of the Code of Federal Regulations requires agency heads to designate every covered position at a high, moderate, or low risk level based on the position’s potential for adverse impact on the efficiency or integrity of the federal service, and positions at the high or moderate risk level are normally treated as public trust positions. The regulation is published in full on eCFR, 5 CFR Part 731, Suitability.
Positions that involve access to classified information or that could otherwise affect national security are designated separately under 5 CFR Part 1400, which sorts national security positions into noncritical sensitive, critical sensitive, or special sensitive levels depending on the degree of potential damage a compromise of that position could cause. That regulation is published at eCFR, 5 CFR Part 1400, Designation of National Security Positions. In practice, agencies commonly describe the resulting investigation levels as tiers, running from Tier 1 for non sensitive, low risk positions up through Tier 5 for special sensitive, top secret eligible positions, with Tier 2 and Tier 4 covering moderate and high risk public trust work and Tier 3 covering noncritical sensitive national security positions. The Office of Personnel Management, working with the Defense Counterintelligence and Security Agency, maintains a Position Designation Tool that agencies use to apply this framework consistently, described on OPM’s Position Designation Tool page.
SF 85: non sensitive, low risk positions
The SF 85, Questionnaire for Non Sensitive Positions, is the shortest of the three forms and applies to positions designated non sensitive and low risk, generally corresponding to Tier 1. It asks for basic biographical information, residence and employment history, education, and references, but it does not include the extensive sections on foreign contacts, foreign activities, and financial history that appear in the other two forms. The current form is published directly by OPM at OPM, Standard Form 85. A low risk designation does not mean no investigation happens. It means the government has decided the position’s duties carry limited potential for harm if something in the applicant’s background turns out to be a concern, so the required investigation is narrower than what a public trust or national security position requires.
SF 85P: public trust positions
The SF 85P, Questionnaire for Public Trust Positions, applies to positions designated moderate risk or high risk under 5 CFR Part 731, generally corresponding to Tier 2 and Tier 4. These are positions with significant program responsibility, law enforcement duties, public health or safety impact, fiduciary responsibility, or access to financial systems or records, where misconduct or bad judgment could cause real damage even though the role does not involve access to classified national security information. The form itself is available at OPM, Standard Form 85P, and it asks for more detail than the SF 85, including financial and foreign contact questions that scale with the risk level of the position. A public trust designation is a suitability and fitness determination, not a security clearance, even though the paperwork and investigative depth can look similar to what a clearance requires.
SF 86: national security positions
The SF 86, Questionnaire for National Security Positions, is the form used when a position is designated noncritical sensitive, critical sensitive, or special sensitive under 5 CFR Part 1400, generally corresponding to Tier 3 and Tier 5. This is the form associated with actually obtaining eligibility for access to classified information, whether that eligibility tops out at Secret or extends to Top Secret and above. The SF 86 is the longest and most detailed of the three, with extended sections on foreign travel, foreign contacts, foreign financial interests, prior clearances, and any history that could bear on trustworthiness or susceptibility to foreign influence. It is published at OPM, Standard Form 86. Filling out an SF 86 does not by itself grant a clearance. It starts an investigation and adjudication process that determines whether the person meets the standard for the access their position requires.
| Form | Position type | Approximate tier | Governing regulation |
|---|---|---|---|
| SF 85 | Non sensitive, low risk | Tier 1 | 5 CFR Part 731 |
| SF 85P | Public trust, moderate or high risk | Tier 2 and Tier 4 | 5 CFR Part 731 |
| SF 86 | National security, noncritical to special sensitive | Tier 3 and Tier 5 | 5 CFR Part 1400 |
How the paperwork actually gets submitted
Applicants do not typically mail a paper SF 85, SF 85P, or SF 86 today. The questionnaires are completed electronically through the government’s investigation intake systems, historically the electronic Questionnaires for Investigations Processing system and, more recently, the eApp system that is part of the National Background Investigation Services platform referenced on OPM’s Position Designation Tool page. The electronic system routes the completed questionnaire, along with fingerprints and any required releases, to the investigative agency handling the case.
Who conducts the investigation
For years, OPM’s own investigations arm handled most federal background investigation work. Since 2019, the majority of federal background investigations, across civilian agencies as well as the Department of Defense, have been conducted by the Defense Counterintelligence and Security Agency, the Department of Defense component that now serves as the government’s primary personnel vetting provider. OPM’s suitability program continues to set suitability policy and adjudicate certain cases, and it explicitly identifies the Defense Counterintelligence and Security Agency as its partner in building and maintaining the Position Designation Tool that agencies rely on, described at OPM’s Position Designation Tool page. Which office conducts a given investigation, and how long it takes, depends on the hiring agency, the position’s tier, and current caseloads, so applicants should not assume a fixed schedule and should ask their hiring agency for status rather than relying on a general estimate.
What the investigation typically checks
Across all three forms, investigators generally verify the residence, employment, and education history the applicant reported, contact listed references and sometimes people who were not listed, and run criminal history and credit checks appropriate to the position’s risk level. 5 CFR Part 731 specifically authorizes OPM to set minimum investigative requirements correlated to risk level, and requires that positions subject to investigation also receive the appropriate sensitivity designation, as described in the same 5 CFR Part 731 text. For national security positions under the SF 86, the scope expands to include foreign contacts, foreign travel, foreign financial interests, and in some cases interviews with the applicant and people who know them, reflecting the broader national security sensitivity definitions found in 5 CFR Part 1400. What gets checked for a specific position still depends on its designated tier, and applicants should not assume every investigation covers identical ground.
Adjudicative guidelines and Continuous Vetting
Once an investigation is complete, someone has to decide whether the findings support granting or denying eligibility. For national security positions, that decision is made against a common set of adjudicative guidelines issued by the Director of National Intelligence acting as the government’s Security Executive Agent, commonly referred to by their directive number, SEAD 4. The guidelines look at areas such as financial considerations, foreign influence, personal conduct, and criminal conduct, among others, and weigh the whole person rather than any single factor in isolation.
Historically, people with an existing clearance or public trust designation were reinvestigated on a fixed cycle, often every five or ten years. That periodic model has been largely replaced by Continuous Vetting, an ongoing process that checks criminal, financial, and other records instead of waiting for a scheduled reinvestigation date. OPM’s own suitability policy resources reference enrollment in continuous vetting for non sensitive positions as part of this shift, listed on OPM’s SuitEA policy and guidance page.
Contractors: suitability and clearance are not the same question
Federal contractors are frequently required to go through background screening as well, and it is easy to conflate that requirement with a security clearance, but they are separate questions. A contractor may need a suitability or fitness determination and a Personal Identity Verification credential simply to access a federal facility or system, without ever needing eligibility for classified access. A contractor who does need access to classified information to perform the contract will go through the same SF 86 based investigation and adjudication process as a federal employee in an equivalent position, sponsored by the contracting agency rather than by an employer in the ordinary sense. For a broader look at what agencies expect from contractor screening generally, see our guide to background check requirements for government contractors.
How this differs from an employment background check
A standard employment background check ordered by a private employer is a consumer report governed by the Fair Credit Reporting Act, which requires a standalone disclosure, written authorization, and pre adverse action and adverse action notices if the employer intends to act on what the report shows. The SF 85, SF 85P, and SF 86 process is not a consumer report and is not run by a consumer reporting agency. It is a government personnel vetting process conducted directly by or for federal agencies, governed by suitability and national security regulations rather than the FCRA, and it can result in a suitability determination or a clearance eligibility decision rather than a simple hire or no hire recommendation. The two processes can overlap for some federal contractor roles, but they answer different legal questions. For a closer comparison of these two tracks, see our article on security clearance versus an employment background check.
Frequently asked questions
What is the difference between SF 85, SF 85P, and SF 86?
SF 85 applies to non sensitive, low risk positions, SF 85P applies to public trust positions at moderate or high risk, and SF 86 applies to national security positions that require eligibility for access to classified information. The form required is determined by how the position is designated under 5 CFR Part 731 or 5 CFR Part 1400, not by job title alone.
Does the Defense Counterintelligence and Security Agency conduct every federal background investigation now?
DCSA conducts the majority of federal background investigations since the function largely moved to the Department of Defense in 2019, but OPM retains suitability policy and adjudication responsibilities, and some agencies retain their own investigative authority. Applicants should confirm with their hiring agency which office is handling their specific case.
Is a public trust designation the same as a security clearance?
No. A public trust designation under the SF 85P is a suitability and fitness determination tied to the position’s risk level, not eligibility for access to classified information. A security clearance eligibility decision is made through the SF 86 process under national security sensitivity designations in 5 CFR Part 1400.
How long does a federal background investigation take?
Timelines vary by tier, by agency, and by current investigative caseloads, and no fixed duration is promised for any case. Applicants should ask the hiring agency for a status update rather than relying on a general estimate found elsewhere.
What is Continuous Vetting?
Continuous Vetting is an ongoing records check process that has largely replaced the older model of reinvestigating cleared and public trust employees on a fixed multi year schedule, so that relevant financial, criminal, and other records are reviewed on an ongoing basis instead.
Do federal contractors fill out the same forms as federal employees?
A contractor who needs eligibility for classified access completes the same SF 86 based process as an employee in an equivalent position. Contractors who only need facility or system access without classified access may instead go through a suitability or credentialing process rather than a security clearance investigation.
Reveal Background provides FCRA compliant employment screening for the private sector employers who hire around this federal ecosystem, distinct from the government personnel vetting process described here. Learn more at Reveal Background.
This article is general information, not legal advice. Federal suitability and security clearance rules, forms, and processing agencies change, and individual cases vary, so confirm current requirements with the hiring agency or OPM before relying on any of it.
