September 2017 

POSITION DESIGNATION

As required by section 1400.201(b) of title 5, Code of Federal Regulations (CFR), this system is for uniform and consistent position designation of:

a) 1

National security positions in the competitive service, the excepted service where the incumbent can be noncompetitively converted to the competitive 

service, and Senior Executive Service (SES) positions held by career appointees in the SES within the executive branch; 

b) 2All “covered positions” as defined in 5 CFR 731.101; 

c) 3

Other excepted service positions within the executive branch and contractor positions, when authorized by agency policy and to the extent consistent 

with law, or when directed by the Security Executive Agent; and

d) 4Any positions, including contractor employee positions, when the investigation will be conducted under the Federal Investigative Standards prescribed by 

the Office of Personnel Management and the Office of the Director of National Intelligence in December 2012.

To determine the proper designation of a position and its required corresponding level of investigation, the position description and any other necessary 

supplemental information (e.g. human resources, management and security office input) must be carefully evaluated to assess the nature of the position as it 

relates to the potential material adverse impact to the national security, and -– if it is a covered position under part 731 -- its impact on the efficiency or integrity 

of the service. 

The following position designation system consists of a four-step process that will guide the designator through an examination of the position’s duties and 

responsibilities. The completion of this process will result in a final designation for the position which, in turn, will determine the investigative requirements for the 

position in question. 

It is important to keep in mind that for covered positions as defined in 5 CFR part 731, the designator must look at both national security and public trust duties 

and responsibilities. Some duties accounted for herein occur under both the national security and public trust sections of the process because of the duty’s 

potential impact on one concern and/or the other. For covered positions, a critical-sensitive or special-sensitive national security designation automatically confers 

high-risk public trust designation, and a noncritical-sensitive national security designation automatically confers a moderate-risk public trust designation unless, as 

described in the following sections of the position designation system, it requires a higher designation. See 5 CFR 1400.201(c), (d). 

 

1 5 CFR 1400.102(b)

2 5 CFR 731.106(a)

3 5 CFR 1400.102(b)

4 Pursuant to an assignment of functions under section 2.2(e) of E.O. 13467, the December 2012 Federal Investigative Standards apply to investigations for 

contractor employee fitness.
BACK to list of National Security duties (Step 1) 2

POSITION DESIGNATION RECORD 

Agency

Position Title

Series and Grade/Pay Band

Position Description Number

Designator’s Name & Title

Step 1.A.: National Security Requirements of the Position:

The designation of national security positions is outlined in part 1400 of title 5, Code of Federal Regulations. Each position in the Federal 

service must be evaluated for a position sensitivity designation commensurate with the responsibilities and assignments of the position as 

they relate to the impact on the national security. Such responsibilities and assignments include, but are not limited to, access to classified 

information (i.e., Confidential, Secret, or Top Secret) and any other duties by which the occupant could bring about a material adverse effect 

on the national security by virtue of the nature of the position. See 5 CFR 1400.102(a) and 1400.201(a). Such positions will be designated, 

based upon the degree of potential damage, at one of three sensitivity levels: Noncritical-Sensitive, Critical-Sensitive, or Special-Sensitive. 

Read the position description and obtain any other supplemental information needed to assess the position duties and responsibilities. 

The regulation sets forth a list of general categories of national security position requirements, duties, and responsibilities. Mark next to all 

of the categories of duties and responsibilities that apply to the position. If any of the categories are marked on this page, go to Step 1.B. to 

assess the degree of potential material adverse impact to national security. 

(Note that underlined words and phrases appearing on this page and throughout the following pages are further defined in the 

attached Glossary.)
BACK to list of National Security duties (Step 1) 3

NATIONAL SECURITY POSITION REQUIREMENTS, DUTIES AND RESPONSIBILITIES5: 

[ ] Requires eligibility for access to classified information (page 4) 

[ ] Homeland security and duties involving protecting the nation’s borders, ports, critical infrastructure or key resources (page 5)

[ ] Developing plans or policies related to national defense or military operations (page 6)

[ ] Planning or conducting intelligence or counterintelligence activities, counterterrorism activities or related activities concerned with the

preservation of the military strength of the United States (page 7)

[ ] Protecting or controlling access to facilities or information systems (page 8) 

[ ] Controlling, maintaining custody, safeguarding, or disposing of hazardous materials, arms, ammunition or explosives (page 9)

[ ] Investigative or adjudicative duties related to national security, suitability, fitness or identity credentialing (page 10)

[ ] Duties related to criminal justice or law enforcement (page 11)

[ ] Conducts internal or external investigations, inquiries or audits of the functions listed here in Step 1 (page 12)

[ ] National security policy-making or policy-determining responsibility (page 13)

[ ] Public health and safety (page 14)

[ ] Fiduciary responsibility in support of activities with national security impact (page 15)

[ ] Unclassified information (e.g. private, controlled unclassified, or proprietary information) (page 16)

[ ] Other duties that could otherwise bring about a material adverse effect on the national security (page 16) Explain: 

_______________________________________________________________________________________________________

If none of the categories are marked continue to Step 2.A., starting on page 17.

 

5 If using the system to designate contractor positions, you assess the duties the incumbent will be performing for or on behalf of the Federal 

Government, not the duties the incumbent performs for their contractor employer. For example, a position may have various national security 

responsibilities performing work specifically for or on behalf of the Federal Government; however, a peripheral responsibility of the position, 

specifically performed for their contractor employer, might involve audits of the contractor staff functions and performance related to the national 

security contract the employer maintains with the Federal Government. This peripheral duty should not be considered when designating the 

contractor position. In other words, the designator should not select “Investigation, oversight, and audits of government personnel, programs, 

and activities” as a duty to be assessed in the context of the position's potential to bring about a material adverse effect on the national security 

because that duty is not being performed for or on behalf of the Federal Government. 
BACK to list of National Security duties (Step 1) 4

Step 1.B.: Determine the potential damage to the national security. 

For each duty/responsibility category you checked in Step 1.A., use the charts below, working from left to right, to identify the appropriate degree 

of potential damage to the national security that the occupant could bring about by virtue of the nature of the position.6

 Check only one column 

per duty. If you select either of the first two columns on the left, no further assessment after 1.B. is needed. After making your selection, you 

will find the resulting position designation and further instruction in the bottom row of the checked column. You must complete this process (i.e. 

assess the entire corresponding table) for each duty category selected in Step 1.A., unless you have selected the first column, resulting in a 

designation of Automatic Special-Sensitive/High Risk, which would require no further assessment and would direct you to proceed to Step 4.

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave 

Damage

Significant or Serious Damage No Material Adverse Effect on 

National Security

Requires eligibility 

for access to 

classified 

information 

[ ] Position requires 

eligibility for access to 

Sensitive Compartmented 

Information (SCI), other 

intelligence-related Special 

Sensitive information, or 

involvement in Top Secret 

Special Access Programs 

(SAP)

[ ] Position requires eligibility 

for access to Top Secret or “Q” 

level information

[ ] Position requires eligibility for

access to Secret, Confidential, or “L” 

level information

[ ] Position does not require eligibility 

for access to classified information 

Position 

Designation

-Automatic Special-Sensitive

/High Risk; No further 

assessment necessary; 

proceed to Step 4.

-Automatic Critical-Sensitive/High 

Risk, unless a subsequent 

assessment resulting in SpecialSensitive is made; Assess any 

remaining selections from Step 

1.A., and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., and 

then assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 

-Non-Sensitive; Assess any remaining 

selections from Step 1.A., and then assess 

under Public Trust (Step 2), unless a 

subsequent assessment directs you to 

proceed to Step 4. 

 

6 Charts are derived from the regulations. See 5 CFR 1400.201. 
BACK to list of National Security duties (Step 1) 5

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse 

Effect on National 

Security

Homeland security 

and aggression, 

including duties 

involving protecting 

borders, ports, 

critical 

infrastructure or 

key resources 

(Protecting the 

U.S., its citizens 

and residents, 

borders, ports, 

critical 

infrastructure7

, and 

key resources8

(CIKR))

[ ] One or more of the following 

when there is the potential to cause 

inestimable damage to national 

security:

• Independent responsibility for, 

and the ability to act without 

detection to compromise or 

exploit, the protection, control, 

and safety of the nation’s 

borders and ports, immigration 

or customs control or policies, 

• Independent responsibility for 

protecting CIKR against acts of 

terrorism, espionage, or foreign 

aggression

• Independent responsibility for 

life-critical/mission-critical 

systems

• Independent responsibility for, 

and the ability to act 

independently without detection 

to compromise or exploit, the 

design, installation, operation, 

or maintenance of CIKR systems 

or programs

[ ] One or more of the following when 

there is the potential to cause exceptionally 

grave damage to national security:

• Major and immediate responsibility for, 

and the ability to act independently 

without detection to compromise or 

exploit, the protection, control, and 

safety of the nation’s borders and ports, 

immigration or customs control or 

policies 

• Major and immediate responsibility, with 

the ability to act independently, for 

protecting CIKR against acts of 

terrorism, espionage, or foreign 

aggression

• Major and immediate responsibility for 

significant life-critical/mission-critical 

systems, with potential for exceptionally 

grave damage to essential government 

operations or national infrastructure

• Major and immediate responsibility for, 

and the ability to act independently 

without detection to compromise or 

exploit, the design, installation, 

operation, or maintenance of CIKR 

systems or programs

[ ] One or more of the following when 

there is the potential to cause 

significant or serious damage to 

national security:

• Responsibility for the protection, 

control, and safety of the nation’s 

borders and ports, immigration or 

customs control or policies – with 

moderate autonomy or ability for 

independent action

• Responsibility for protecting CIKR 

against acts of terrorism, 

espionage, or foreign aggression – 

with moderate autonomy or ability 

for independent action

• Responsibility for lifecritical/mission-critical systems – 

with moderate autonomy or ability 

for independent action

• Involved in the design, 

installation, operation, or 

maintenance of critical 

infrastructure systems or 

programs – with moderate 

autonomy or ability for 

independent action

[ ] Duties are of such a minor 

or inconsequential nature, with 

autonomy limited by 

supervision, and/or internal 

controls are so significant that 

there is no reasonable 

expectation that there could be 

significant or serious damage to 

national security

Position 

Designation

-Automatic Special-Sensitive /High 

Risk; No further assessment 

necessary; proceed to Step 4.

-Automatic Critical-Sensitive/High Risk, 

unless a subsequent assessment resulting 

in Special-Sensitive is made; Assess any 

remaining selections from Step 1.A., and 

then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., and 

then assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 

-Non-Sensitive; Assess any 

remaining selections from Step 

1.A., and then assess under Public 

Trust (Step 2), unless a 

subsequent assessment directs 

you to proceed to Step 4.

 7

 Critical infrastructures are systems and assets, whether physical or virtual, so vital to the United States that the incapacity or destruction of such systems and assets 

would have a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters. 5 CFR 1400.102(a)(1) 8

 Key resources are publicly or privately controlled resources essential to the minimal operations of the economy and government. 5 CFR 1400.102(a)(2)
BACK to list of National Security duties (Step 1) 6

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave 

Damage

Significant or Serious Damage No Material Adverse Effect on 

National Security

Developing plans 

and policies related 

to national defense 

or military 

operations

[ ] Position requires 

eligibility for access to 

Sensitive Compartmented 

Information (SCI), other 

intelligence-related Special 

Sensitive information, or 

involvement in Top Secret 

Special Access Programs 

(SAP)

[ ] One or more of the 

following: 

• Development or approval of 

war plans

• Development or approval of 

major or special military 

operations

• Development or approval of 

critical and extremely 

important items of war

[ ] Any knowledge of military 

operations or items of war the 

compromise of which could result in 

significant or serious damage to the 

national security 

[ ] Knowledge is of such a minor or 

inconsequential nature and/or internal 

controls are so significant that there 

is no reasonable expectation that 

there could be significant or serious 

damage to national security

Position 

Designation

-Automatic Special-Sensitive

/High Risk; No further 

assessment necessary; 

proceed to Step 4.

-Automatic Critical-Sensitive/High 

Risk, unless a subsequent 

assessment resulting in SpecialSensitive is made; Assess any 

remaining selections from Step 

1.A., and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., and 

then assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 

-Non-Sensitive; Assess any remaining 

selections from Step 1.A., and then assess 

under Public Trust (Step 2), unless a 

subsequent assessment directs you to 

proceed to Step 4. 
BACK to list of National Security duties (Step 1) 7

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect on 

National Security

Planning or 

conducting 

intelligence or

counterintelligence 

activities, 

counterterrorism

activities or related 

activities concerned 

with the 

preservation of the 

military strength of 

the United States

[ ] One or more of the 

following when there is the 

potential to cause inestimable 

damage to national security:

• Knowledge of, planning 

for, or participation in 

significant and important 

activities related to 

intelligence, 

counterintelligence, or 

counterterrorism – with 

complete authority or 

freedom to act 

independently

• Identification, disruption,

or neutralization of, or 

protection against, 

hostile intelligence or 

terrorist activities – with 

complete authority or 

freedom to act 

independently

• Activities are critical and 

extremely important to 

the preservation of the 

military strength of the 

United States 

[ ] One or more of the following 

when there is the potential to 

cause exceptionally grave 

damage to national security:

• Knowledge of, planning for, 

or participation in significant 

and important activities 

related to intelligence, 

counterintelligence, or 

counterterrorism – with 

broad authority or freedom 

to act independently

• Identification, disruption, or 

neutralization of, or 

protection against, hostile 

intelligence or terrorist

activities – with broad 

authority or freedom to act 

independently

• Activities are critical and 

extremely important to the 

preservation of the military 

strength of the United 

States 

[ ] One or more of the following 

when there is the potential to cause 

significant or serious damage to 

national security:

• Knowledge of, planning for, or 

participation in significant and 

important activities related to 

intelligence, counterintelligence, 

or counterterrorism – with 

limited autonomy or ability for 

independent action

• Identification, disruption, or 

neutralization of, or protection 

against, hostile intelligence or 

terrorist activities – with limited 

autonomy or ability for 

independent action

[ ] No direct involvement in 

planning or conducting 

intelligence, counterintelligence, or 

counterterrorism activities that are 

important to preserving National 

Security; any knowledge of such 

activities is of such a minor or 

inconsequential nature, and/or 

internal controls are so significant, 

that there is no reasonable 

expectation that there could be 

significant or serious damage

national security

Position 

Designation

-Automatic Special-Sensitive /High 

Risk; No further assessment 

necessary; proceed to Step 4.

-Automatic Critical-Sensitive/High 

Risk, unless a subsequent 

assessment resulting in SpecialSensitive is made; Assess any 

remaining selections from Step 1.A., 

and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., and 

then assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 

-Non-Sensitive; Assess any remaining 

selections from Step 1.A., and then 

assess under Public Trust (Step 2), 

unless a subsequent assessment 

directs you to proceed to Step 4. 
BACK to list of National Security duties (Step 1) 8

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect on 

National Security

Protecting or 

controlling access 

to facilities or 

information 

systems 

(Duties encompass 

responsibilities 

exceeding basic 

Personal Identity 

Verification (PIV) 

card vetting, 

processing, and 

issuance) 

[ ] One or more of the 

following when there is the 

potential to cause inestimable 

damage to national security:

• Independent 

responsibility for identity 

vetting and/or 

unrestricted access to 

materials for producing 

credentials and badges, 

the compromise of which 

could result in inestimable 

damage to the national 

security 

• Unlimited access to 

and/or control of access 

to designated restricted 

areas or facilities, 

property, or information 

systems that maintain 

materials or national 

security information 

classified at the SCI level

[ ] One or more of the following 

when there is the potential to 

cause exceptionally grave 

damage to national security:

• Independent responsibility 

for identity vetting and/or 

unrestricted access to

materials for producing 

credentials and badges, the 

compromise of which could 

result in grave damage to 

the national security

• Access to and/or controlling 

access to designated 

restricted areas, property, or 

information systems that 

house materials or 

information (including but 

not limited to Top Secret or 

“Q” information)

[ ] One or more of the following 

when there is the potential to cause 

significant or serious damage to 

national security, through limited 

autonomy:

• Responsibility for identity vetting 

and/or access to materials for 

producing credentials and 

badges permitting access to 

facilities or information systems, 

the compromise of which could 

result in significant or serious 

damage to the national security

• Access to and/or controlling 

access to designated restricted 

areas or facilities, property, 

information systems that 

maintain materials or national 

security classified at the Secret, 

Confidential or “L” level

[ ] Duties are of such a minor or 

inconsequential nature and/or 

internal controls are so significant 

that there is no reasonable 

expectation that there could be 

significant or serious damage to 

national security

Position 

Designation

-Automatic Special-Sensitive /High 

Risk; No further assessment 

necessary; proceed to Step 4.

-Automatic Critical-Sensitive/High 

Risk, unless a subsequent 

assessment resulting in SpecialSensitive is made; Assess any 

remaining selections from Step 1.A., 

and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., and 

then assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 

-Non-Sensitive; Assess any remaining 

selections from Step 1.A., and then 

assess under Public Trust (Step 2), 

unless a subsequent assessment 

directs you to proceed to Step 4. 
BACK to list of National Security duties (Step 1) 9

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect on 

National Security

Controlling,

maintaining

custody,

safeguarding, or

disposing of

hazardous

materials, arms,

ammunition or

explosives 

[ ] Position requires 

eligibility for access to 

Sensitive Compartmented 

Information (SCI), other 

intelligence-related Special 

Sensitive information, or 

involvement in Top Secret 

Special Access Programs 

(SAP)

[ ] One or more of the following 

when there is the potential to 

cause exceptionally grave damage

to national security: 

• Ability to independently 

compromise or exploit 

biological select agents or 

toxins, chemical agents, 

nuclear materials, or other 

hazardous materials

• Ability to independently 

compromise or exploit the 

nation’s nuclear or chemical 

weapons designs or systems

• Direct, unrestricted control 

over supplies of arms, 

ammunition, or explosives or 

control over any weapons of 

mass destruction

[ ] One or more of the following 

when there is the potential to cause 

significant or serious damage to 

national security, through limited 

autonomy: 

• Limited access or control over 

biological select agents or toxins, 

chemical agents, nuclear materials, 

or other hazardous materials

• Limited access or control over the 

nation’s nuclear or chemical 

weapons designs or systems

• Limited access or control over 

supplies of arms, ammunition, or 

explosives or control over any 

weapons of mass destruction

[ ] Duties are of such a minor or

inconsequential nature and/or internal

controls are so significant that there

is no reasonable expectation that 

there could be significant or serious 

damage to national security

Position 

Designation

-Automatic Special-Sensitive

/High Risk; No further 

assessment necessary; 

proceed to Step 4.

-Automatic Critical-Sensitive/High 

Risk, unless a subsequent 

assessment resulting in SpecialSensitive is made; Assess any 

remaining selections from Step 1.A., 

and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., and 

then assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 

-Non-Sensitive; Assess any remaining 

selections from Step 1.A., and then assess 

under Public Trust (Step 2), unless a 

subsequent assessment directs you to 

proceed to Step 4. 
BACK to list of National Security duties (Step 1) 10

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious 

Damage

No Material Adverse Effect on 

National Security

Investigative or 

adjudicative duties 

related to national 

security, suitability, 

fitness or identity 

credentialing 

[ ] One or more of the following 

when there is the potential to 

cause inestimable damage to 

national security: 

• Investigative duties (includes 

conducting counterintelligence or background 

investigations or handling 

completed investigations 

classified at the SCI level)

• National security adjudicative 

determinations, or granting 

personnel security clearance 

eligibility, or making other 

adjudicative determinations 

(such as suitability, fitness, or 

credentialing determinations) 

for positions at the specialsensitive level

• Duty on personnel security 

boards for SCI eligibility 

determinations

[ ] One or more of the following:

• Investigative duties at tiers 3, 

4 and 5 of the Federal 

Investigative Standards (FIS)

(includes handling completed

counter-intelligence or 

background investigations)

• Adjudicative determinations 

(includes adjudicative 

recommendations) concerning 

national security, suitability, 

fitness, credentialing, or 

granting personnel security 

clearance eligibility for 

positions investigated at tiers 

3, 4 and 5 of the FIS

• Duty on personnel security 

boards

[ ] One or more of the 

following: 

• Investigative duties at tiers 

1 and 2 of the FIS 

(includes handling 

incomplete or parts of 

counter-intelligence or 

background investigations 

• Adjudicative 

determinations (includes 

adjudicative 

recommendations) 

concerning suitability, 

fitness or credentialing 

eligibility for positions 

investigated at tiers 1 and 

2 of the FIS

[ ] Duties are of such a minor or 

inconsequential nature and/or

internal controls are so significant 

that there is no reasonable 

expectation that there could be 

significant or serious damage to

national security

Position 

Designation

-Automatic Special-Sensitive /High 

Risk; No further assessment 

necessary; proceed to Step 4.

-Automatic Critical-Sensitive/High Risk, 

unless a subsequent assessment 

resulting in Special-Sensitive is made;

Assess any remaining selections from 

Step 1.A., and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 

1.A., and then assess under Public 

Trust (Step 2), unless a 

subsequent assessment directs you 

to proceed to Step 4.

-Non-Sensitive; Assess any remaining 

selections from Step 1.A., and then 

assess under Public Trust (Step 2), 

unless a subsequent assessment 

directs you to proceed to Step 4. 
BACK to list of National Security duties (Step 1) 11

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect 

on National Security

Duties related to 

criminal justice or 

law enforcement 

affecting national 

security matters

[ ] One or more of the following 

where the incumbent’s neglect, action 

or inaction could cause inestimable 

damage to national security:

• Independent responsibility for 

coordinating and/or conducting 

criminal investigations concerning 

highly sensitive matters 

• Independent responsibility for 

criminal justice or law 

enforcement activities 

[ ] One or more of the following where 

the incumbent’s neglect, action or 

inaction could cause exceptionally grave 

damage to national security:

• Major and immediate responsibility 

for coordinating and/or conducting 

criminal investigations concerning 

highly sensitive matters 

• Major and immediate responsibility 

for criminal justice or law 

enforcement activities

[ ] One or more of the following 

where the incumbent’s neglect, action 

or inaction could cause significant or 

serious damage to national security:

• Conducting criminal investigations, 

with moderate autonomy or 

potential for independent action, 

concerning sensitive matters 

• Conducting criminal justice or law 

enforcement activities, with 

moderate autonomy or potential 

for independent action, concerning 

sensitive matters 

• Responsibility for the protection, 

control and enforcement of the 

nation’s public health or safety 

policies – with moderate autonomy 

or ability to negatively impact or 

damage national security

• Responsibility for protecting the 

nation’s public health or safety 

against acts of terrorism, 

espionage, or foreign aggression– 

with moderate autonomy or ability 

to negatively impact or damage 

national security

[ ] Duties are of such a minor or 

inconsequential nature and/or 

internal controls and supervision 

are so significant that there is no 

reasonable expectation that there 

could be significant or serious 

damage to national security

Position 

Designation

-Automatic Special-Sensitive /High 

Risk; No further assessment 

necessary; proceed to Step 4.

-Automatic Critical-Sensitive/High Risk, 

unless a subsequent assessment 

resulting in Special-Sensitive is made;

Assess any remaining selections from 

Step 1.A., and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., 

and then assess under Public Trust 

(Step 2), unless a subsequent 

assessment directs you to proceed to 

Step 4.

-Non-Sensitive; Assess any 

remaining selections from Step 

1.A., and then assess under Public 

Trust (Step 2), unless a 

subsequent assessment directs you 

to proceed to Step 4.
BACK to list of National Security duties (Step 1) 12

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect 

on National Security

Conducts internal 

and/or external 

investigations, 

inquiries, or audits 

related to national 

security functions 

listed in Step 1

[ ] Conducts internal and/or 

external investigations, inquiries, 

or audits related to national 

security matters where neglect, 

action or inaction could cause 

inestimable damage to national 

security 

[ ] Conducts internal and/or 

external investigations, inquiries, or 

audits related to national security 

matters where neglect, action, or 

inaction could cause exceptionally 

grave damage to the national 

security 

[ ] Conducts internal and/or 

external investigations, inquiries, 

or audits related to national 

security matters where neglect, 

action, or inaction could cause 

significant or serious damage to 

the national security

[ ] Involvement with internal 

and/or external investigations,

inquiries or audits is so minor or 

inconsequential in nature 

and/or internal controls are so 

significant that there is no 

reasonable expectation that 

there could be significant or 

serious damage to national 

security

Position 

Designation

-Automatic Special-Sensitive /High 

Risk; No further assessment 

necessary; proceed to Step 4.

-Automatic Critical-Sensitive/High Risk, 

unless a subsequent assessment 

resulting in Special-Sensitive is made;

Assess any remaining selections from 

Step 1.A., and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., 

and then assess under Public Trust 

(Step 2), unless a subsequent 

assessment directs you to proceed to 

Step 4.

-Non-Sensitive; Assess any 

remaining selections from Step 

1.A., and then assess under Public 

Trust (Step 2), unless a 

subsequent assessment directs you 

to proceed to Step 4.
BACK to list of National Security duties (Step 1) 13

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect 

on National Security

National security

policy-making or 

policy-determining 

responsibility 

[ ] One or more of the following 

when there is the potential to 

cause inestimable damage to 

national security:

• Senior management officials 

for critical government 

programs impacting 

national security

• Independent responsibility 

for national security policymaking or policydetermining 

• Direct involvement with 

diplomatic relations and 

negotiations, with the ability 

to act independently

• Independent, agency 

spokesperson concerning 

extremely 

sensitive/controversial 

matters for critical 

government programs 

impacting national security

• Independent responsibility 

for planning or approving 

continuity of government 

operations 

[ ] One or more of the following 

when there is the potential to cause 

exceptionally grave damage to 

national security:

• Senior management officials 

for key government programs 

impacting national security

• Major and immediate 

responsibility for national 

security policy-making or 

policy-determining 

• Direct involvement with 

diplomatic relations and 

negotiations

• Independent, agency 

spokesperson concerning 

sensitive/controversial matters 

for key government programs 

impacting national security

• Independent responsibility for 

planning or approving 

continuity of government 

operations 

[ ] One or more of the following 

when there is the potential to 

cause significant or serious 

damage to national security:

• Management duties in 

government programs that 

impact national security

• Substantial responsibility 

supporting individuals 

directly involved with 

diplomatic relations and 

negotiations

• Substantial responsibility for 

developing policies, 

regulations and/or rulemaking for significant 

government programs 

affecting national security

• Substantial responsibility 

supporting individuals 

serving as agency 

spokesperson concerning 

national security matters

• Serves in advisory role to 

senior agency officials who 

complete one or more of the 

above duties

[ ] One or more of the 

following: 

• Policy input is limited to 

providing unclassified or 

non-sensitive technical input 

or administrative support

• Other duties related to policy 

with no potential to cause 

significant or serious 

damage to the national 

security 

• Policy and program 

responsibility is related to 

public trust in the efficiency 

and integrity of the service 

rather than national security

Position 

Designation

-Automatic Special-Sensitive /High 

Risk; No further assessment 

necessary; proceed to Step 4.

-Automatic Critical-Sensitive/High Risk, 

unless a subsequent assessment 

resulting in Special-Sensitive is made;

Assess any remaining selections from 

Step 1.A., and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., 

and then assess under Public Trust 

(Step 2), unless a subsequent 

assessment directs you to proceed to 

Step 4.

-Non-Sensitive; Assess any 

remaining selections from Step 

1.A., and then assess under Public 

Trust (Step 2), unless a 

subsequent assessment directs you 

to proceed to Step 4.
BACK to list of National Security duties (Step 1) 14

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect 

on National Security

Public health and 

safety

For example, National 

security concerns 

related to:

• Food supply safety 

• Drug safety

• Pandemic disease 

prevention and 

control

• Urgent public health 

threats

• Transportation 

system safety 

(aviation, highway, 

railroad, and 

maritime)

[ ] One or more of the 

following when there is the 

potential to cause inestimable 

damage to national security 

with devastating results of 

a widespread or 

incapacitating nature:

• Independent responsibility 

for the protection, control 

and enforcement of the 

nation’s public health or 

safety policies, with the 

ability to act without 

detection to compromise 

national security with 

devastating results

• Independent responsibility 

for protecting the nation’s 

public health or safety 

against acts of terrorism, 

espionage, or foreign 

aggression, with the ability 

to act without detection to 

compromise national 

security with devastating 

results

[ ] One or more of the following 

when there is the potential to cause 

exceptionally grave damage to 

national security (effect may be 

regional, or multi-state, or the 

impact is controllable within a 

reasonable period of time and 

expending moderate resources): 

• Major and immediate 

responsibility for the protection, 

control and enforcement of the 

nation’s public health or safety 

policies, with the ability to act 

independently without detection 

to compromise national security 

with devastating results

• Major and immediate 

responsibility for protecting the 

nation’s public health or safety 

against acts of terrorism, 

espionage, or foreign aggression, 

with the ability to act 

independently without detection 

to compromise national security 

with devastating results

[ ] One or more of the following 

when there is the potential to 

cause significant or serious 

damage to national security

(effect may be local or isolated to 

a single location, or the impact is 

controllable within a reasonable 

period of time and expending 

minimal resources) :

• Responsibility for the 

protection, control and 

enforcement of the nation’s 

public health or safety policies 

– with moderate autonomy or 

ability to negatively impact or 

damage national security

• Responsibility for protecting the 

nation’s public health or safety 

against acts of terrorism, 

espionage, or foreign 

aggression– with moderate 

autonomy or ability to 

negatively impact or damage 

national security

[ ] Duties are of such a minor 

or inconsequential nature 

and/or internal controls are so 

significant that there is no 

reasonable expectation that 

there could be a material 

adverse effect on national 

security 

Position 

Designation

-Automatic Special-Sensitive /High 

Risk; No further assessment 

necessary; proceed to Step 4.

-Automatic Critical-Sensitive/High Risk, 

unless a subsequent assessment 

resulting in Special-Sensitive is made;

Assess any remaining selections from 

Step 1.A., and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., 

and then assess under Public Trust

(Step 2), unless a subsequent 

assessment directs you to proceed to 

Step 4.

-Non-Sensitive; Assess any 

remaining selections from Step 

1.A., and then assess under Public 

Trust (Step 2), unless a 

subsequent assessment directs you 

to proceed to Step 4.
BACK to list of National Security duties (Step 1) 15

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect 

on National Security

Fiduciary 

responsibility in 

support of activities 

with national 

security impact9

[ ] Position requires 

eligibility for access to 

Sensitive Compartmented 

Information (SCI), other 

intelligence-related Special 

Sensitive information, or 

involvement in Top Secret 

Special Access Programs

(SAP)

[ ] One or more of the following when 

there is the potential to cause 

exceptionally grave damage to national 

security: 

• Obligates, expends, collects or 

controls revenue or funds in excess of 

$50 million

• Procures or secures funding for goods 

and/or services with monetary value 

in excess of $50 million annually

• Obligates or controls items with a 

monetary value in excess of $50 

million 

• Audits or analyzes budgets or other

financial records 

[ ] One or more of the following 

when there is the potential to cause 

significant or serious damage to 

national security:

• Obligates, expends, collects or 

controls revenue or funds material 

to national security

• Procures or secures funding for 

goods and/or services with 

monetary value material to 

national security

• Obligates or controls items with a 

monetary value material to 

national security

• Audits or analyzes budgets or 

other financial records

[ ] Fiduciary responsibilities 

are of such a minor or 

inconsequential nature and/or 

internal controls are so 

significant that there is no 

reasonable expectation that 

there could be significant or 

serious damage to national 

security 

Position 

Designation

-Automatic Special-Sensitive

/High Risk; No further 

assessment necessary; 

proceed to Step 4.

-Automatic Critical-Sensitive/High Risk, 

unless a subsequent assessment resulting in 

Special-Sensitive is made; Assess any 

remaining selections from Step 1.A., and then 

proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., and 

then assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 

-Non-Sensitive; Assess any 

remaining selections from Step 

1.A., and then assess under Public 

Trust (Step 2), unless a 

subsequent assessment directs you 

to proceed to Step 4.

 

9 If the dollar amount associated with fiduciary duties is unknown, obtain sufficient information about the responsibilities of the position, including 

the level of authority, the scope of impact, the potential to cause damage to the national security, and to establish whether the potential damage 

is significant or serious, exceptionally grave or inestimable. (For example, some considerations might include the scope of contracts funded, the 

extent of operations a budget affects, whether the individual will have signature authority to obligate funds, etc.)
BACK to list of National Security duties (Step 1) 16

Degree of Potential Damage to the National Security

Duties/ 

Responsibilities

Inestimable Damage Exceptionally Grave Damage Significant or Serious Damage No Material Adverse Effect on 

National Security

Unclassified 

information (e.g. 

private, controlled 

unclassified, or 

proprietary 

information) 

significant to 

national security

[ ] Unlimited access to and 

control over unclassified 

information, which may 

include private, proprietary 

or other controlled 

unclassified information 

when there is the potential 

to cause inestimable damage

to national security

[ ] Unlimited access to and 

control over unclassified 

information, which may include 

private, proprietary or other 

controlled unclassified 

information, but only where the 

unauthorized disclosure of that 

information could cause 

exceptionally grave damage to 

national security 

[ ] Limited access to and control over 

unclassified information, which may 

include private, proprietary or other 

controlled unclassified information, but 

only where the unauthorized disclosure 

of that information could cause 

significant or serious damage to 

national security

[ ] Access to unclassified 

information is minimal and is of such 

a minor or inconsequential nature 

and/or internal controls are so 

significant that there is no 

reasonable expectation that there 

could be significant or serious 

damage to national security

Other duties that 

could otherwise 

bring about a 

material adverse 

effect on national 

security

[ ] Other duties, when there 

is the potential to cause 

inestimable damage to 

national security; explain:

[ ] Other duties, when there is 

the potential to cause 

exceptionally grave damage to 

national security; explain:

[ ] Other duties, when there is the 

potential to cause significant or serious 

damage to national security; explain:

[ ] Duties are so minor or 

inconsequential in nature and/or

internal controls are so significant 

that there is no reasonable 

expectation that there could be 

significant or serious damage to 

national security

Position 

Designation

-Automatic Special-Sensitive

/High Risk; No further 

assessment necessary; 

proceed to Step 4.

-Automatic Critical-Sensitive/High 

Risk, unless a subsequent 

assessment resulting in SpecialSensitive is made; Assess any 

remaining selections from Step 1.A., 

and then proceed to Step 4.

-Non-Critical Sensitive; Assess any 

remaining selections from Step 1.A., and 

then assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 

-Non-Sensitive; Assess any remaining 

selections from Step 1.A., and then 

assess under Public Trust (Step 2), 

unless a subsequent assessment directs 

you to proceed to Step 4. 
17

Step 2.A.: Suitability Requirements

The designation of covered positions is outlined in section 731.106 of title 5, Code of Federal Regulations. Every covered position must be designated at 

the low, moderate, or high risk level as determined by the position's potential for adverse impact on the efficiency and integrity of the service. As the level of 

authority and responsibility of a position becomes greater, character and conduct become more significant in deciding whether employment or continued 

employment would protect the integrity or promote the efficiency of the Federal service. 5 CFR 731.106(b) set forth general categories of public trust position 

requirements, duties, and responsibilities. Read the position description and obtain any other necessary information (e.g. management input) to determine if 

any of the following duties apply to the position. (The focus of this preliminary review should be on the actual duties of the position rather than on the 

agency mission or the program in which the position is located.)10 Mark next to the categories of duties that apply to the position. If any of the categories 

are marked, go to Step 2.B. In Step 2.B., you will further evaluate the position’s duties to determine the degree to which any misconduct could impact on the 

efficiency or integrity of the service. 

PUBLIC TRUST POSITION REQUIREMENTS, DUTIES, AND RESPONSIBILITIES (UNRELATED TO NATIONAL SECURITY): 

[ ] Government operations – rulemaking, policy, and major program responsibility (includes regulation or policy making, directing, implementing, advising and 

audits) (page 18) 

[ ] Public safety and health services, regulation, enforcement, and protection (Food safety and inspection, occupational health and safety, transportation safety, 

environmental safety and hazard mitigation) (page 19) 

[ ] Law Enforcement or criminal justice duties (page 19) 

[ ] Protection of government funds for non-national security operations (page 20) 

[ ] Customs, Immigration, and/or Critical Infrastructure and Key Resources (page 21) 

[ ] Hazardous material handling and transportation (page 21) 

[ ] Physical security, controlling facility or physical access to information technology, and/or controlled access to arms, ammunitions, or explosives (page 22) 

[ ] Investigation, oversight, and audits of government personnel, programs, and activities (page 22) 

[ ] Adjudication of matters or claims (other than national security, suitability, fitness, or credentialing) with the potential to impact the public’s trust (page 23) 

[ ] Protection of government information technology systems (supervision or control of information technology systems, authority to bypass significant technical 

and operational security controls for general support systems, or access to major applications – the scope of these duties exceed that of ordinary or routine 

computer use) (page 24) 

[ ] Protection of personal, private, controlled unclassified, or proprietary information with the potential to damage the public’s trust (includes access to or 

processing of personal information such as that protected by the Privacy Act (PA) of 1974, exempt from disclosure under the Freedom of Information Act 

(FOIA), financial data, or privileged information involving the award of contracts, contractor proprietary information, etc.) (page 25) 

[ ] Government service delivery, including customer service or public liaison duties (page 25) 

[ ] Other activities demanding a degree of public trust (Specify any other specific duties that are not otherwise covered): (page 26) 

____________________________________________________________________________________________________________

If none of the above categories are marked, the position is designated “low risk.” Continue to Step 4, and consider this result in 

combination with the results from Step 1 to determine the appropriate level of investigation for the position. 

 10 If using the system to designate contractor positions, you assess the duties the incumbent will be performing for or on behalf of the Federal 

Government, not the duties the incumbent performs for their contractor employer. For example, a position may involve customer service or liaison 

between the contractor and the Federal Government, just as a natural part of doing business. However, if the work being performed for or on behalf of 

the Federal Government does not involve customer service or liaison (e.g. providing telephonic customer service/information concerning a government 

program), then you would not select “Government service delivery, including customer service or public liaison duties” as a duty to be assessed in the 

context of the position's potential for adverse impact on the efficiency and integrity of the service. 
BACK to list of Public Trust duties (Step 2A) 18

Step 2.B.: Determine the potential impact of the position on the efficiency or integrity of the service (public trust). 

For each duty identified in Step 2.A., use the charts below, working from left to right, to identify the appropriate degree of potential damage to 

the public trust from misconduct. Check only one column per duty. 

Note: At a minimum, supervisors or managers should be included at the same level as their employees, whether or not they personally 

do the work described, since they hold responsibility for the outcome of the work.

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Government 

operations – 

rulemaking, policy 

and major

program 

responsibility 

(includes 

regulation or policy 

making, directing, 

implementing, 

advising and 

audits) 

[ ] Senior management 

official for critical government 

programs, the compromise of 

which could result in grave 

damage to the public’s trust

[ ] One or more of the 

following: 

• Senior management duties or 

assignments that do not rise 

to the level of an automatic 

High-Risk condition 

• Substantial responsibility for 

approving regulations and/or 

rule-making agendas for 

significant government 

programs impacting the 

public’s trust

• Independent responsibility for 

planning or approving 

continuity of government 

operations

• Sets policy for significant 

government programs

impacting the public’s trust

• Independent agency 

spokesperson concerning 

delicate controversial matters

impacting the public’s trust

• Serves in advisory role to 

senior agency officials who 

complete one or more of the 

above duties

[ ] One or more of the 

following: 

• Mid-level management 

duties or assignments

• Assists agency rulemakers or policy decisionmakers for significant 

public trust government 

programs in an influential 

way

• Responsible for 

independent or semiindependent action with 

moderate impact on 

efficiency and integrity or 

the service

• Significant public contact 

about important 

government programs

impacting the public’s 

trust

[ ] One or more of the 

following: 

• Management duties with 

less than moderate impact

on programs

• Regulation or policy input is 

limited to contributing to 

working groups or 

providing technical input
BACK to list of Public Trust duties (Step 2A) 19

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Public safety and 

health services, 

regulation, 

enforcement, and 

protection (Food 

safety and 

inspection, 

occupational 

health and safety, 

transportation 

safety, 

environmental 

safety and hazard 

mitigation) 

[ ] Immediate, significant, and 

independent responsibility for

protecting the public’s health 

and safety in areas outside of 

national security, such as: 

• Food safety and inspection

• Occupational health and 

safety

• Transportation safety 

enforcement

• Environmental safety

• Environmental hazard 

mitigation

[ ] Position is actively, 

operationally engaged in 

services related to the duties 

in this category (but has only 

moderate ability to impact the 

public’s trust), such as:

• Performing inspections

• Enforcing established 

standards

• Providing regulatory advice 

and direction

[ ] The position aids or 

supports the duties in this 

category; however, the 

responsibilities are so narrow 

in scope or carried out under 

such restrictive controls that 

the risk of violating the public’s 

trust is very limited 

Law enforcement 

or criminal justice 

duties

[ ] Conducts criminal 

investigations concerning 

delicate criminal matters, the 

compromise of which could 

cause grave damage to 

public’s trust

[ ] One or more of the 

following: 

• Scope of authority is very 

broad (full arrest authority 

within a large jurisdiction)

• Regular possession and use 

of a firearm in an open, 

uncontrolled environment 

(e.g., in a large jurisdiction; 

work environment has no 

physical boundaries)

• Conducts criminal 

investigations 

• Responsible for criminal 

justice matters involving 

delicate or controversial 

matters the compromise of 

which would cause severe 

damage to the public’s trust

[ ] One or more of the 

following: 

• Scope of authority is 

extensive, but arrest 

authority is within a small 

jurisdiction 

• Use/possession of a 

firearm within a small 

jurisdiction 

• Conducts criminal 

investigations concerning 

routine matters

• Exercises custodial control 

over inmates, detainees, 

suspects, etc.

• Monitors or supervises 

individuals in the custody 

of a criminal justice 

system or process, i.e., 

probation or parole 

officers, etc.

[ ] One or more of the 

following: 

• Criminal justice or law 

enforcement duties that do 

not require possession and 

use of a firearm 

• Authority is very limited in 

nature 

• Position provides aid or 

supports the duties in this 

category
BACK to list of Public Trust duties (Step 2A) 20

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Protection of 

government 

funds11 for nonnational security

operations, access 

to or operation or 

control of financial 

records, fiduciary 

responsibilities or 

other duties (such 

as developing 

statements of 

work) with a 

significant risk for 

causing damage 

or with the 

potential for 

realizing significant 

personal gain

[ ] One or more of the 

following, where the impact is 

to the public’s trust: 

• Obligates, expends, 

collects or controls 

revenue, funds or items 

with monetary value in 

excess of $50 million

• Procures (or secures 

funding for) goods and/or 

services with monetary 

value in excess of $50 

million annually, with the 

potential for devastating 

impact on government 

programs or operations

[ ] One or more of the 

following: 

• Obligates, expends, collects 

or controls revenue, funds or 

items with monetary value in 

excess of $10 million, but less 

than $50 million annually

• Audits or analyzes budgets or 

other financial records, the 

compromise of which could 

cause significant impact on 

government programs or 

operations

• Procures (or secures funding 

for) goods and/or services 

with monetary value in 

excess of $10 million, but less 

than $50 million, annually, 

with potential for significant 

impact on government 

programs or operations

[ ] One or more of the 

following: 

• Obligates, expends, 

collects or controls funds 

or items with monetary 

value over $1 million, but 

under $2 million, annually, 

where the ability to ensure 

effective oversight is 

limited; or $2 million to 

$10 million annually

• Audits or analyzes 

budgets or other financial 

records, with potential for 

moderate impact on 

government programs or 

operations 

• Procures (or secures 

funding for) goods and/or 

services with monetary 

value exceeding $2 

million, but less than $10 

million, annually, the 

compromise of which 

could cause moderate 

impact on government 

programs or operations

[ ] One or more of the 

following:

• Obligates, expends, 

collects or controls funds 

or items with monetary 

value of less than $2 

million, but only when 

meaningful controls are in 

place to monitor the 

process and detect abuse; 

Otherwise, value may not 

exceed $1 million

• Audits or analyzes budgets 

or other financial records, 

with potential for limited 

impact on government 

programs or operations

• Procures (or secures 

funding for) goods and/or 

services with monetary 

value less than $2 million 

annually the compromise of 

which could cause limited 

impact on government 

programs or operations 

 

11 If the dollar amount associated with fiduciary duties is unknown, obtain sufficient information about the responsibilities of the position, including 

the level of authority, the scope of impact, and the potential to realize personal gain, to establish whether the risk is severe, moderate, or limited. 

(For example, some considerations might include the scope of contracts funded, the extent of operations a budget affects, whether the individual 

will have signature authority to obligate funds, etc.)
BACK to list of Public Trust duties (Step 2A) 21

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Customs, 

Immigration, 

and/or Critical 

Infrastructure and 

Key Resources

(CIKR)

(Duties in this 

category do not

impact national 

security; 

however, there 

exists inherent 

public trust in 

the fulfillment of 

these 

responsibilities.)

[ ] One or more of the following

with autonomy controlled 

through system or physical 

means: 

• Position has immediate, 

significant, and independent 

responsibility for facilitating: 

o Citizenship and 

immigration services

o Enforcing immigration law

o Customs enforcement

o Deterring unauthorized 

employment

o Other similar 

responsibilities 

• Position has immediate and 

significant responsibilities for 

the operation and 

administration of CIKR 

[ ] One or more of the 

following with autonomy 

controlled through system or 

physical means: 

• Position is actively, 

operationally engaged in, 

or provides direct material 

support to: 

o Providing citizenship 

and immigration 

services

o Enforcing immigration 

law 

o Customs enforcement

o Deterring unauthorized 

employment

o Other similar 

responsibilities 

• Position provides 

operational support or

administration support of 

CIKR

[ ] The position aids or 

supports the duties in this 

category; however, the duties 

of the job are so narrow in

scope or carried out under 

such restrictive controls that 

the risk of violating the public’s 

trust is very limited

Hazardous 

material handling

and transportation 

(such as medical 

waste, mechanical 

or industrial waste, 

(i.e. waste 

chemicals, fuel, oil, 

batteries, etc.)) 

[ ] Significant, independent 

responsibility for the disposition, 

handling or transportation of 

hazardous materials, with the 

ability to circumvent procedural, 

physical and oversight processes 

[ ] Responsibilities include 

the handling or transportation 

of hazardous materials; 

however, effective 

procedural, physical and 

oversight processes are 

employed to significantly 

minimize any violation of the 

public’s trust 

[ ] Any potential compromise

of the public’s trust through 

employee negligence,

malfeasance or deliberate 

intent is virtually eliminated 

through oversight and controls
BACK to list of Public Trust duties (Step 2A) 22

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Physical security, 

controlling facility 

or physical access 

to information 

technology, and/or 

controlled access 

to arms, 

ammunition, or 

explosives, but not 

to the extent that 

there is an impact 

on national 

security

[ ] One or more of the 

following: 

• Responsibility for non-PIV,

facility access credentials,

with no national security

impact

• Access to materials for

producing credentials and

badges

• Access control (physical

access, not logical access)

over high-impact information

systems

[ ] One or more of the 

following: 

• Access to moderate

supplies of arms,

ammunition, or explosives,

in other than national

security operations;

however, effective

procedural, physical and

oversight processes are

employed to significantly

minimize any violation of

the public’s trust

• Access control (physical

access, not logical access)

over moderate or lowimpact information

systems

[ ] One or more of the 

following: 

• Any potential compromise

of the public’s trust through

employee negligence,

malfeasance or deliberate

intent is essentially

eliminated through

oversight and controls

• Security guard positions

not requiring

use/possession of a firearm

or involved in controlling

access to restricted areas

Investigation, 

oversight, and 

audits of 

government 

personnel, 

programs, and 

activities 

[ ] One or more of the 

following: 

• Very broad authority in the

conduct of internal and/or

external non-criminal

investigations, inquiries, or

audits concerning delicate or

controversial matters (for

example, Office of Inspector

General investigations), with

impact to the public’s

trust

• Any other non-criminal

investigative or

oversight/auditing duties, the

outcome or compromise of

which could cause severe

harm to the public’s trust

[ ] Conducts, under limited 

authority, internal and/or 

external non-criminal 

investigations, inquiries, or 

audits, the outcome or 

compromise of which could 

negatively impact the 

public’s trust

[ ] Conducts or assists in 

conducting Government 

investigations, inquiries, or 

audits of a routine nature, but 

has very limited opportunity

for independent action
BACK to list of Public Trust duties (Step 2A) 23

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Adjudication of 

matters or claims 

(other than national 

security, suitability, 

fitness, or 

credentialing) with 

the potential to 

impact the public’s 

trust 

[ ] Adjudicates delicate or 

controversial matters, the 

nature of which could cause 

grave damage to the public’s 

trust, but no impact to 

national security

[ ] Adjudicates delicate or 

controversial public trust matters 

and claims, the outcome or 

compromise of which could 

impact the public’s trust or 

the mission of the underlying 

Government program, its 

fairness, efficiency, and integrity

[ ] Adjudicates other

matters and claims (those not 

considered delicate or 

controversial), the outcome 

or compromise of which could 

cause harm to the health, 

safety, or financial security of 

individuals affected by the 

adjudication, or to the 

public’s trust in the 

underlying Government 

program

[ ] Adjudicates other matters 

and claims where there is 

limited potential for harm 

and/or limited opportunity for 

independent action
BACK to list of Public Trust duties (Step 2A) 24

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Protection of 

government 

information 

technology

systems12 

[ ] One or more of the 

following: 

• Develops/directs/ 

implements/administers 

agency computer security 

programs, including risk 

analysis/threat assessment 

without technical review

• Disburses or authorizes 

disbursement of $10 million 

per year or greater from 

computer systems 

• Major responsibility for the 

direction, planning, design, 

testing, maintenance, 

operation, monitoring, and/or 

management of systems

hardware or software

• Automated access to a 

system during operation or 

maintenance or preparation 

of data for entry into a 

computer system in any way 

that creates high risk for 

causing severe damage or 

realizing significant personal 

gain (for example, the ability 

to independently manipulate 

data) 

[ ] One or more of the 

following: 

• Work carried out under 

technical review of a 

higher authority that 

involves direction, 

planning, design, 

operation, testing, 

maintenance, or 

monitoring of a computer 

system 

• Automated access to or 

processing of information 

systems that in any way 

creates moderate risk for 

causing damage or 

realizing moderate 

personal gain

• Disburses or authorizes 

disbursement of less than 

$10 million from computer 

systems 

[ ] Aids or supports the 

duties in this category; 

however, the responsibilities 

are so narrow in scope or 

carried out under such 

restrictive controls that the risk 

of violating the public’s trust is 

practically eliminated

 

12 Includes access to or processing of controlled unclassified information, supervision or control of information technology systems, authority to 

bypass significant technical and operational security controls for general support systems, or access to major applications. The scope of these 

duties exceed that of ordinary or routine computer use.
BACK to list of Public Trust duties (Step 2A) 25

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Protection of 

personal, private, 

controlled 

unclassified or 

proprietary 

information 

(including PA and 

FOIA, etc.), the 

nature of which 

does not impact 

national security

[ ] Unlimited access and control 

over personal, private, 

proprietary, or controlled 

unclassified information, the 

unauthorized disclosure of which 

could severely impact the 

public’s trust, through 

substantial damage/harm to: 

• The integrity or efficiency of 

the service

• Individuals or business 

entities 

• Government programs or 

operations impacting the 

public’s trust

[ ] Access and control over 

personal, private, proprietary, 

or controlled unclassified 

information, the unauthorized 

disclosure of which could 

negatively impact the public’s 

trust, through serious 

damage/harm to: 

• The integrity or efficiency 

of the service

• Individuals or business 

entities 

• Government programs or 

operations impacting the 

public’s trust

[ ] One or more of the 

following:

• Access to personal, private, 

proprietary, or controlled 

unclassified information, the 

unauthorized disclosure of 

which could cause very 

limited damage to 

individuals, business 

entities, or government 

programs or operations or 

any potential damage is

limited to the local level

• Duties are carried out under 

such restrictive controls that 

the risk of violating the 

public’s trust is extremely 

limited 

Government 

service delivery, 

including customer 

service and public 

liaison duties

[ ] Customer service

responsibilities and/or public 

liaison that could cause 

inestimable damage to the 

public’s trust through grave 

damage/harm to: 

• The integrity or efficiency 

of the service

• Individuals or business 

entities 

• Government programs or 

operations impacting the 

public’s trust

[ ] Duties involve customer 

service responsibilities and/or 

public liaison that could severely 

impact the public’s trust through 

severe damage/harm to: 

• The integrity or efficiency of 

the service

• Individuals or business 

entities 

• Government programs or 

operations impacting the 

public’s trust

[ ] Duties involve customer 

service responsibilities and/or 

public liaison that could 

negatively impact the public’s 

trust through moderate 

damage/harm to: 

• The integrity or efficiency 

of the service

• Individuals or business 

entities 

• Government programs or 

operations impacting the 

public’s trust

[ ] Duties involve customer 

service responsibilities and/or 

public liaison that could cause 

limited damage to individuals, 

business entities, or 

government programs or 

operations 
BACK to list of Public Trust duties (Step 2A) 26

Degree of Potential Damage to the Public Trust from Misconduct

Duties/ 

Responsibilities

Automatic High-Risk 

Conditions

Severe impact Moderate impact Limited impact

Other activities 

demanding public 

trust (describe 

unique factors, 

considerations not 

previously 

accounted for)

[ ] Explain: [ ] Explain: [ ] Explain: [ ] Explain:

If any block in this column 

is checked, skip step 3 

and go to Step 4. 

Depending upon the 

results of Step 1, the 

position will be

designated either:

• Non-critical Sensitive

/High Risk or

• Non-Sensitive/High Risk 

(Public Trust)

Total blocks checked in this 

column:

( ____ X 50 = ____ ) 

 (x)

Total blocks checked in 

this column:

( ____ X 15 = ____ ) 

 (y)

Total blocks checked in 

this column:

( ____ X 1 = _____ )

 (z)

Total Risk Points x + y + z =__________ 

 (Add totals from all three columns above) 

 Go to Step 3 and enter this number in the chart

 
27

Step 3: Point adjustment for program designation and level of supervision. 

In the Chart below, choose the appropriate adjustment value for the scope of program impact and the level of related controls from the Total Risk 

Points identified in step 2. (Only one column will apply) 

Enter the total Risk Points from Step 2 into one of the appropriate columns (sections)

(50 and above) 

__________

(16 to 49)

___________

(15 and under)

__________

Adjustment for Scope of Program and 

Correlation to Extent of Impact

[ ] Worldwide or government-wide impact13

– no change

[ ] Multi-agency impact14 – subtract 5 

points

[ ] Agency impact15 – subtract 10 points

Adjustment for Scope of Program and 

Correlation to Extent of Impact

[ ] Worldwide or government-wide impact13 – 

add 15 points

[ ] Multi-agency impact14 – no change

[ ] Agency impact15 – subtract 10 points

 

Adjustment for Scope of Program and 

Correlation to Extent of Impact

[ ] Worldwide or government-wide impact13 – 

add 15 points

[ ] Multi-agency impact14 – add 5 points

[ ] Agency impact15 – subtract 5 points

Adjustment for level of supervision or 

other controls

[ ] Limited or no supervision - ability to act 

independently in almost all areas almost all of 

the time – no change

[ ] Periodic, ongoing review – ability to act 

independently a lot of the time – subtract 5 

points

[ ] Close technical supervision –ability to act 

independently infrequently – subtract 10

points

Adjustment for level of supervision or 

other controls

[ ] Limited or no supervision - ability to act 

independently in almost all areas almost all of 

the time – add 15 points

[ ] Periodic, ongoing review – ability to act 

independently a lot of the time – no change

[ ] Close technical supervision –ability to act 

independently infrequently – subtract 10 

points

Adjustment for level of supervision or 

other controls

[ ] Limited or no supervision - ability to act 

independently in almost all areas almost all of 

the time – add 15 points

[ ] Periodic, ongoing review – ability to act 

independently a lot of the time – add 5 points

[ ] Close technical supervision –ability to act 

independently infrequently – subtract 5 

points

Final Adjusted Risk Points: Final Adjusted Risk Points: Final Adjusted Risk Points:

 

13 Program operations have potential to affect the entire government or have global implications. Misconduct or damage would have potential for 

a national to international impact of a broad nature on the United States government or other countries and/or the individuals or private entities 

affected by the Government. 14 Program operations affect more than one agency. Misconduct or damage would have potential to impact multiple government agencies, and/or 

the individuals or private entities affected by those agencies.

15 Program operations affect only one agency. Misconduct or damage would have potential for a local impact on the agency, and/or the 

individuals or private entities affected by the agency.
28

Step 4: Final Position Designation and Investigation.

Use the following chart to determine the final position designation and required investigative Tier. Note that for those positions 

designated as “Non-Sensitive” or “Noncritical-Sensitive”, the over-riding consideration in the final designation depends on the 

risk designation level (Final Adjusted Risk Points from Step 3) associated with the public trust responsibilities of the position. 

Sensitivity: _______________________ Risk:_______________________ Level of Investigation:_________ Form Type: ______

Designator’s Signature: _________________________________________________________________ Date:________________

16 5 CFR 1400.201(c) directs that critical-sensitive or special-sensitive level designations shall automatically be designated as high risk 17 5 CFR 1400.201(d) directs that non-critical sensitive level designations shall automatically be designated as moderate risk, unless the agency 

determines the position should be designated at the high risk level

National Security 

Sensitivity Designation 

from Step 1.B

Risk Designation from 

Step 2.B. or 3 

Final Position 

Designation

Level of 

Investigation 

per 2012 

Federal 

Investigative 

Standards

Form Type

“Special-Sensitive” or 

“Critical-Sensitive” “High Risk”16

Special-Sensitive or 

Critical-Sensitive/

High Risk

Tier 5 SF 86

“Noncritical-Sensitive”

50 or more Final 

Adjusted Risk Points: 

“High Risk” 

Noncritical-Sensitive/

High Risk Tier 5 SF 86

49 or fewer Final 

Adjusted Risk Points : 

“Moderate Risk”17 

Noncritical-Sensitive/

Moderate Risk Tier 3 SF 86

“Non-Sensitive” 

(No national security 

sensitivity) 

50 or more Final 

Adjusted Risk Points : 

“High Risk” 

Non-Sensitive/

High Risk (Public Trust) Tier 4 SF 85P

16 to 49 Final Adjusted 

Risk Points: 

“Moderate Risk”

Non-Sensitive/

Moderate Risk (Public 

Trust)

Tier 2 SF 85P

15 or fewer Final 

Adjusted Risk Points : 

“Low Risk”

Non-Sensitive/

Low Risk Tier 1 SF 85
29

GLOSSARY

TERM DEFINITION

AGENCY An Executive agency, which is defined by 5 U.S.C. 105 as an Executive department, a 

Government corporation, and an independent establishment.

AUTOMATIC HIGH-RISK CONDITIONS 

FOR PUBLIC TRUST

These conditions are duties that present the possibility of the gravest impact to the public’s trust, 

likely to produce inestimable damage. The degrees of potential impact are broadly defined. It is 

necessary to look at each public trust duty and evaluate the entire row of example duties 

provided to establish context to determine the scope of potential impact to the public’s trust. This 

reveals the potential damage to the integrity and efficiency of the service and the public’s trust.

CLOSE TECHNICAL SUPERVISION Continuing review of all work by a technical expert, such as:

1. The supervisor provides continuing or individual assignments by indicating generally

what is to be done, limitations, quality and quantity expected, deadlines, and priority of

assignments.

2. The supervisor provides additional, specific instructions for new, difficult, or unusual

assignments, including suggested work methods or advice on source material available.

The employee uses initiative in carrying out recurring assignments independently without

specific instructions, but refers deviations, problems, and unfamiliar situations not

covered by instructions to the supervisor for decision or help. The supervisor assures

that finished work and methods used are technically accurate and in compliance with

instructions or established procedures. Review of the work increases with more difficult

assignments if the employee has not previously performed similar assignments.

3. For both one-of-a-kind and repetitive tasks, the supervisor makes specific assignments

accompanied by clear, detailed, and specific instructions. The employee works as

instructed and consults with the supervisor as needed on all matters not specifically

covered in the original instructions or guidelines. For all positions the work is closely

controlled. For some positions, the control is through the structured nature of the work;

for others, it may be controlled by the circumstances in which it is performed. In some

situations, the supervisor maintains control through review of the work. This may include

checking progress or reviewing completed work for accuracy, adequacy, and adherence

to instructions and established procedures.
30

TERM DEFINITION

CRITICAL-SENSITIVE POSITIONS As defined in 5 CFR 1400.201(a)(2), critical-sensitive positions are, “national security positions 

which have the potential to cause exceptionally grave damage to the national security.” Also, in 

accordance with 5 CFR 1400.201(c) a critical-sensitive position automatically carries with it a risk 

designation under 5 CFR 731.106 at the high level.

CRITICAL AND EXTREMELY IMPORTANT 

ITEMS OF WAR

Those items vital to success in war, or without which success would be unlikely.

CUSTOMER SERVICE Customer care duties that support the delivery of an agency’s services. The scope of the word 

“customer” would be defined based upon the duties outlined in the position description. For 

example, one agency’s customers might be other Government agencies, but a different agency 

may primarily serve non-Government entities or the general public (e.g. the duties of employees 

with the General Services Administration vs. those of a Social Security Administration employee); 

however, that is not to suggest every employee of those agencies would be assumed to have 

customer service responsibilities; that is defined by the specific duties of the job.

DAMAGE TO THE NATIONAL SECURITY E.O. 13526 characterizes damage to the national security as “harm to the national defense or 

foreign relations of the United States from the unauthorized disclosure of information, to include 

sensitivity, value, and utility of that information.”

EXCEPTIONALLY GRAVE DAMAGE TO 

THE NATIONAL SECURITY

The capacity to cause extremely serious harm to the national security. Also, the minimum level of 

damage an incumbent’s neglect, action or inaction must have the potential to cause for a 

position to be designated as critical-sensitive. 

INESTIMABLE DAMAGE TO THE 

NATIONAL SECURITY

The capacity to cause harm to the national security too severe to be computed or measured. 

Also, the minimum level of damage an incumbent’s neglect, action or inaction must have the 

potential to cause for a position to be designated as special-sensitive.

INFORMATION TECHNOLOGY As defined in OMB Circular A-130, information technology is, “any equipment or interconnected 

system or subsystem of equipment, that is used in the automatic acquisition, storage, 

manipulation, management, movement, control, display, switching, interchange, transmission, or 

reception of data or information by an executive agency. For purposes of the preceding 

sentence, equipment is used by an executive agency if the equipment is used by the executive 

agency directly or is used by a contractor under a contract with the executive agency which (i) 

requires the use of such equipment, or (ii) requires the use, to a significant extent, of such 

equipment in the performance of a service or the furnishing of a product. The term "information 

technology" includes computers, ancillary equipment, software, firmware and similar procedures, 

services (including support services), and related resources. The term "information technology" 

does not include any equipment that is acquired by a Federal contractor incidental to a Federal 

contract. The term "information technology" does not include national security systems as 

defined in the Clinger-Cohen Act of 1996 (40 U.S.C. 1452).”
31

TERM DEFINITION

INFORMATION SYSTEM As defined in OMB Circular A-130 an information system is, “a discrete set of information 

resources organized for the collection, processing, maintenance, transmission, and dissemination 

of information, in accordance with defined procedures, whether automated or manual.”

LIMITED IMPACT TO THE PUBLIC’S 

TRUST

Likely to produce some harm or discernible damage to the public’s trust. The degrees of 

potential impact are broadly defined. It is necessary to look at each public trust duty and 

evaluate the entire row of example duties provided to establish context to determine the scope 

of potential impact to the public’s trust. This reveals the potential damage to the integrity and 

efficiency of the service and the public’s trust.

LIMITED OR NO SUPERVISION Occasional review from a perspective of major policy issues by a superior who likely has no 

relevant expertise in the technical aspects of the duties performed. 

The supervisor provides administrative direction with assignments in terms of broadly defined 

missions or functions. The employee has responsibility for independently planning, designing, 

and carrying out programs, projects, studies, or other work. Results of the work are considered 

technically authoritative and are normally accepted without significant change. If the work should 

be reviewed, the review concerns such matters as fulfillment of program objectives, effect of 

advice and influence on the overall program, or the contribution to the advancement of 

technology. Recommendations for new projects and alteration of objectives usually are evaluated 

for such considerations as availability of funds and other resources, broad program goals, or 

national priorities.

MODERATE IMPACT TO THE PUBLIC’S 

TRUST

Likely to produce a fair amount of harm or serious damage to the public’s trust. The degrees of 

potential impact are broadly defined. It is necessary to look at each public trust duty and 

evaluate the entire row of example duties provided to establish context to determine the scope 

of potential impact to the public’s trust. This reveals the potential damage to the integrity and 

efficiency of the service and the public’s trust.

NATIONAL SECURITY As defined in 5 CFR 1400.102(a), national security “refers to those activities which are directly 

concerned with the foreign relations of the United States, or protection of the Nation from 

internal subversion, foreign aggression, or terrorism.”

NATIONAL SECURITY POSITION As defined in 5 CFR 1400.102(a), a national security position, “includes any position in a 

department or agency, the occupant of which could bring about, by virtue of the nature of the 

position, a material adverse effect on the national security.”

NONCRITICAL-SENSITIVE POSITIONS As defined in 5 CFR 1400.201(a)(1) noncritical-sensitive positions are, “national security positions 

which have the potential to cause significant or serious damage to the national security”. Also, in 

accordance with 5 CFR 1400.201(d) a noncritical-sensitive position automatically initially carries 

with it a risk designation under 5 CFR 731.106 at the moderate level, unless the agency 

determines that the position should be designated at the high level. Agencies shall designate the 

position at the high level where warranted on the basis of criteria set forth in OPM issuances as 

described in 5 CFR 731.102(c).
32

TERM DEFINITION

PERIODIC REVIEW Ongoing spot review from a perspective of policy and organizational concerns by a superior with 

expertise in the technical aspects of the duties performed. 

The supervisor sets the overall objectives and resources available. The employee and supervisor, 

in consultation, develop deadlines, projects, and work to be done. The employee, having 

developed expertise in the line of work, is responsible for planning and carrying out the 

assignment, resolving most of the conflicts that arise, coordinating the work with others as 

necessary, and interpreting policy on own initiative in terms of established objectives. In some 

assignments, the employee also determines the approach to be taken and the methodology to be 

used. The employee keeps the supervisor informed of progress and potentially controversial 

matters. Completed work is reviewed only from an overall standpoint in terms of feasibility, 

compatibility with other work, or effectiveness in meeting requirements or expected results. 

OR 

The supervisor makes assignments by defining objectives, priorities, and deadlines and assists 

the employee with unusual situations that do not have clear precedents. The employee plans and 

carries out the successive steps and handles problems and deviations in the work assignments in 

accordance with instructions, policies, previous training, or accepted practices in the occupation. 

Completed work is usually evaluated for technical soundness, appropriateness, and conformity to 

policy and requirements. The methods used in arriving at the end results are not usually 

reviewed in detail.

SEVERE IMPACT TO THE PUBLIC’S 

TRUST

Likely to produce a substantial degree of harm or serious damage to the public’s trust. The 

degrees of potential impact are broadly defined. It is necessary to look at each public trust duty 

and evaluate the entire row of example duties provided to establish context to determine the 

scope of potential impact to the public’s trust. This reveals the potential damage to the integrity 

and efficiency of the service and the public’s trust.

SIGNIFIGANT OR SERIOUS DAMAGE TO 

THE NATIONAL SECURITY

The capacity to cause noteworthy harm to the national security. Also, the minimum level of 

damage an incumbent’s neglect, action or inaction must have the potential to cause for a 

position to be designated as noncritical-sensitive.

SIGNIFIGANT PERSONAL GAIN Noticeably or measurably benefiting an individual’s interests in a substantial way (e.g. a large 

monetary or other valuable personal benefit, benefit to one’s family or friends, etc.; providing a 

level of affluence or a lifestyle otherwise not justifiable).

SPECIAL-SENSITIVE POSITIONS As defined in 5 CFR 1400.201(a)(3) special-sensitive positions are, “national security positions 

which have the potential to cause inestimable damage to the national security.” Also, in 

accordance with 5 CFR 1400.201(c) a special-sensitive position automatically carries with it a risk 

designation under 5 CFR 731.106 at the high level.