U.S. Geological Survey Manual

370.371.1 - Personnel Suitability – Low Risk and Public Trust Positions

This chapter prescribes the U.S. Geological Survey’s (USGS) policies, procedures and standards for determining suitability for Federal employment. 

DATE:   May 18, 2007

OPR:  Office of Human Capital, Office of Human Resources

Instruction:  New Survey Manual Chapter.

1. Purpose.  This chapter prescribes the U.S. Geological Survey’s (USGS) policies, procedures and standards for determining suitability for Federal employment.  Related guidance on personnel security can be referenced in SM 440.3, National Security Information, https://www.usgs.gov/about/organization/science-support/survey-manual/4403-national-security-information.

2. Scope.  The provisions of this chapter cover all Federal employees and positions within the USGS regardless of the type of appointment or position, except as specified below. 

This chapter does not cover appointments in which employees serve on temporary appointments that do not exceed an aggregate of 180 calendar days in either a single continuous or series of appointments in low risk positions.  Suitability for employment to appointments of this nature will be determined through comprehensive reference checks prior to selection to verify information supplied by the applicant and to obtain other information that will assist in a determination as to the individual’s requisite suitability to hold Federal employment. 


A. Executive Order (EO) 10450, Security Requirements for Government Employment; EO 10577, Amending the Civil Service Rules and authorizing a new appointment system for the competitive service.

B. Code of Federal Regulations 5, Part 731, Suitability

C. Departmental Manual 441, Personnel Security and Suitability Requirements

4. Policy.  The USGS will employ and retain in employment only those persons with the requisite suitability of character to hold Federal employment.

5. Definitions.  A glossary of terms and definitions that relate to the Personnel Suitability position program are found in Department Manual 441, Personnel Security and Suitability Requirements, http://elips.doi.gov/app_DM/act_getfiles.cfm?relnum=3323.

6. Responsibilities.  Specific areas of responsibility for implementation of the USGS suitability program are as follows:

A. Director.  The Director is responsible for implementing and administering a bureau personnel suitability program which complies with the requirements of 5 CFR 731, Suitability and DM 441, Personnel Security and Suitability Requirements.

B.Bureau Human Resources Officer.  The Bureau Human Resources Officer is responsible for:

(1)  ensuring that written policies, plans, and procedures have been promulgated that provide for implementation of a comprehensive and effective personnel suitability program within the USGS.

(2)  implementing plans that provide for the designation of program and position suitability for all organizations and positions within the USGS. 

(3)  otherwise providing for the establishment and maintenance of an effective suitability program to ensure that the employment of each person in a competitive service position will promote the efficiency of the service.

C. Bureau Security Manager.  The Bureau Security manager is responsible for:

(1)  providing oversight and review authority for personnel suitability adjudication for public trust positions.

(2)  ensuring review and adjudication of investigations for sensitive and contractor and other affiliate positions and that those individuals authorized to review and adjudicate investigative files on a continuing basis have undergone a favorably evaluated background investigation commensurate with the scope and coverage of the investigative information being reviewed. 

D. Servicing Human Resources Officers.  The Servicing Human Resources Officers are responsible for:

(1) ensuring the supervisor is consulted regarding position duties and responsibilities to be considered by the Human Resources Office in the designation process; that the position risk designation process as described in this chapter is completed; and that designations are made in a consistent and uniform manner across the bureau. 

(2) implementing plans to ensure that the final position sensitivity designation is recorded on a Position Designation Record and the record is maintained with the original position description in the Human Resources Office.

(3) ensuring the position sensitivity designation is recorded in the automated personnel system in a consistent and accurate manner for retrieval and reporting purposes. 

(4) implementing plans to ensure that forms associated with the conduct of personnel investigations are properly initiated, that suitability adjudications are completed for all public trust positions covered by this chapter, and that suitability file documentation in support of the personnel suitability program is properly maintained.

(5) providing for proper training of managers/supervisors, human resources specialists, and administrative personnel in position risk designation, suitability determinations, and other personnel suitability matters.

(6) coordinating and working closely with the Security Management Office staff to ensure that pre-appointment investigation requirements are satisfied, as required, and that the Security Office is notified of all relevant personnel actions for persons in sensitive positions. 

A. Managers, Supervisors or Other Authorized Officials.  Managers, supervisors or other authorized officials are responsible for the following:

(1) reviewing all positions under their authority for the purpose of recommending risk level placement.

(2) consulting with the servicing human resources office to ensure the assignment of the appropriate risk level for all positions under their authority.

(3) continuously monitoring risk level designations for positions under their authority to ensure the accuracy and consistency of those determinations.   

F.  Employees.  Employees are responsible for promptly completing and submitting the required investigative and personnel forms to their servicing human resources officers or designees as appropriate.

G.  Adjudicators.  Adjudicators are responsible for adjudicating personnel background investigations in accordance with the laws, regulations, and criteria pertaining to suitability determinations.  Adjudicators must undergo a background investigation equal to or higher than the cases handled and be trained in adjudication procedures. 

7. Risk Level Designation.

A.  General Information.  All positions in the U.S. Geological Survey require a risk designation for suitability and a position sensitivity designation for national security based on access to national security information.  The level of investigation required is determined by the combined evaluation of 1) risk for suitability and 2) sensitivity for national security access.  The highest level of risk or sensitivity will determine the level of investigation required.  Follow the procedures and guidance found in Survey Manual Chapter 440.7, National Security Position, https://www.usgs.gov/about/organization/science-support/survey-manual/4407-national-security-position-program.  Program for positions requiring access to national security information, data, or systems. 

Every position is designated at the High, Moderate or Low risk level for suitability depending on the position’s potential impact to the integrity and efficiency of the service.  Positions at the High and Moderate Level are referred to as “Public Trust” positions.  These positions generally involve:

  • Policy making responsibility;
  • Major program responsibility;
  • Public safety and health responsibilities;
  • Law enforcement duties;
  • Fiduciary responsibilities; and/or
  • Other activities demanding a significant degree of public trust.

Computer/ADP (Information Technology – IT) position Risk Levels are an integral part of the risk designation process.  Generally, the IT Risk Level assigned to a position is dependent on the assets the position has access to or programmatic or policy responsibility for and the criticality of the asset to the bureau program.  Typically, positions that meet these criteria have:

  • IT security duties and responsibilities;
  • Programmatic or policy level responsibilities for an IT asset;
  • Access to, operate, or have control of systems containing proprietary information or information covered by the Privacy Act, such as financial or personal records; or,
  • Responsibilities involving accounting, disbursement, or authorization to disburse money from Federal systems.    

The specific criteria used to make a position designation for USGS positions are found in the USGS Personnel Suitability Handbook [internal site]. 

B.  Timing of Designation.  All positions must be designated when established.  For Federal positions, this occurs with the position is established and classified by the Human Resources Office.  The supervisor is responsible for initiating a request to redesignate a position when the assignment of work changes such that a risk level is impacted but the position responsibilities do not change sufficiently to warrant a revised position description.  An example of when this situation may occur is when an individual is granted access to an IT asset that requires a higher risk level.   

The request to redesignate a position is to be submitted to the servicing Human Resources Office within two weeks of the new assignment.

8. Initiating Suitability Investigations

A. General.  Position risk level designations, resulting from application of procedures described in Section 7 of this chapter, will determine the type of investigation to be initiated in accordance with the USGS Personnel Suitability Handbook and Departmental policy.  The following forms will be used in initiating background investigations:

  • Standard Form (SF) 85, Questionnaire for Non-Sensitive Positions, will be used for initiating investigations of individuals occupying positions designated as “Non-Sensitive – Low Risk”. 
  • Standard form (SF) 85P, Questionnaire for Public Trust Positions, will be used for initiating investigations of individuals occupying positions designated as “Public Trust – Moderate Risk” or “Public Trust – High Risk”.
  • Processing Standard Form 85 and Standard Form 85P.  The supervisor is responsible for ensuring employees under his/her supervision complete the SF-85 or SF-85P as appropriate when requested by the USGS Human Resources Officer.  When necessary, the Human Resources Office or science center administrative staffs will assist employees to complete and return the appropriate form to the servicing human resources office for submission to the Office of Personnel Management (OPM). 

Forms required to request an investigation are as follows: 


Non-Sensitive Low Risk Position

Public Trust Position
(Moderate or High)

New Federal Appointment

SF-85 – original
SF-87, Fingerprint Chart
OF-306, Optional Application for Federal Employment/Resume

SF-85P– original
SF-87, Fingerprint Chart
OF-306, Optional Application for Federal Employment/Resume


SF-85 – original
SF-87, Fingerprint Chart

SF-85P – original
SF-87, Fingerprint Chart

Update & Upgrade Investigation

SF-85 – original
SF-87, Fingerprint Chart

SF-85P – original
SF-87, Fingerprint Chart

See Requesting OPM Personnel Investigations http://www.opm.gov/extra/investigate/

9. Suitability Determinations (Adjudication)

OPM is responsible for carrying out a program of investigating and adjudicating the suitability of applicants and employees for Federal employment.  Suitability involves assessing identifiable character traits and past conduct sufficiently to determine whether a specific individual is likely to be able to carry out the duties of a Federal job with appropriate efficiency and effectiveness.  OPM provides guidance for making suitability determinations in 5 CFR 731.  Unfavorable decisions are made to promote the efficiency of Government service and only after giving the individual due process rights.  Department of the Interior guidance on Adjudication Standards are found in 441 DM Chapter 5, http://elips.doi.gov/app_DM/act_getfiles.cfm?relnum=3290.

OPM has delegated to agencies the authority for adjudicating suitability, except in competitive service cases involving evidence of material, intentional false statement or deception or fraud in examination or appointment.  In these cases, agencies are required to contact OPM before taking action. 

10.   Administrative Review and Appeal

For Federal employees, applicants, or appointees, the Human Resources Office is responsible for taking appropriate action when an adverse suitability action based on the results of a personnel background investigation, is proposed.  Unfavorable action can be taken under 5 CFR 731, 
5 CFR 752, 5 CFR 315, or any other applicable authority.  The applicant, appointee, or employee must be afforded their rights under all appropriate authorities.


___/s/ Karen D. Baker__________                   _May 18, 2007_______________        
Karen D. Baker                                                                                           Date
Associate Director, Office of Administrative Policy and Services