Modernizing Mental Health Disclosure in Security Vetting

The federal government's approach to security clearance applications is undergoing a significant transformation, particularly regarding how mental health information is collected and evaluated. The Office of Management and Budget approved a new Personnel Vetting Questionnaire in November 2023, which will replace the Standard Form-86 and other legacy forms used for government positions requiring security clearance.

These changes represent a fundamental shift in breaking down longstanding barriers that have discouraged honest disclosure and potentially deterred candidates from pursuing careers requiring security clearances.

The Historical Problem

Before 2016, applicants were required to report whether they had consulted with or been treated by a mental health practitioner within the last seven years. This broad requirement created an environment where individuals faced an impossible choice: seek help for treatable conditions or protect career prospects by avoiding treatment.

Many employees chose not to seek psychological help out of fear of jeopardizing their security clearance eligibility, duty position, and career. The stigma was particularly acute in military and intelligence communities.

Initial Reforms: The 2016 Changes

The first major breakthrough came in 2016. Director of National Intelligence James Clapper announced changes to Section 21 of the SF-86, implemented in November 2016, that were designed to better emphasize the importance of mental health and wellness while protecting national security interests. The revised question focused on whether an individual has a condition that may affect eligibility for access to classified information, rather than on the fact of receiving treatment.

The 2016 revisions were designed to decrease applicant anxiety over mental health questions and encourage those working in the national security sector who needed mental health treatment to get it. Under the updated approach, the requirement that clearance holders disclose any mental health counseling was removed, and clearance holders are now required to disclose only mental health conditions that would substantially adversely affect their judgment, reliability, or trustworthiness.

The New Personnel Vetting Questionnaire: Going Further

The newly approved Personnel Vetting Questionnaire builds on the 2016 reforms with even more significant changes. The PVQ aims to further reduce stigma by limiting the scope of questions even further with questions about specific diagnoses rather than about all mental health treatment.

The PVQ limits many of its questions on psychological and emotional health to hospitalizations and treatments within the past five years, rather than using the "have you ever" questions included in the SF-86. This represents a substantial reduction in the lookback period for mental health disclosures.

Individuals undergoing treatment for common conditions such as anxiety and depression, and those who pursue counseling after trauma or significant stress, are not likely to answer affirmatively to any of the items in the PVQ. This represents the philosophical shift at the heart of these reforms: routine mental health care should not trigger security concerns.

Real-World Impact

The practical implications extend far beyond paperwork. Officials across multiple government agencies and the private sector are working to reduce stigma around mental health issues and encourage workers to seek treatment if needed. This represents a complete reversal from the historical approach that treated mental health care as inherently suspicious.

The impact has been especially significant within military and intelligence sectors. The SF-86 revisions have clarified that general counseling is no longer a required disclosure, only specific conditions, hospitalizations, and issues directly affecting reliability and trustworthiness need to be reported.

As the PVQ rolls out, applicants and organizations alike should stay informed and prepared. While the SF-86 remains in use, now is the time to understand how mental health disclosures, lookback periods, and transparency are being reframed in federal vetting.

At EMT Holdings, we’re watching these changes closely, and we’re here to help professionals, contractors, and agencies navigate the evolving landscape with confidence and compliance.

Until Next Time,

The EMT Holdings Team

www.emt-holdings.com

Info@emt-holdings.com

(703) 637-4561

(The rollout of the Personnel Vetting Questionnaire is ongoing, and details may continue to change.

We’ll keep our readers updated as new guidance is released.)