If you work for the United States federal government or a government contractor and your position requires access to classified information, you’ve almost certainly undergone a thorough background investigation as part of the process of obtaining a security clearance. But getting and retaining security clearance eligibility isn’t a one-time task. Certain events can trigger a reinvestigation, and clearance holders must be aware of how their actions—on and off the job—can lead to renewed scrutiny.

What Is a Security Clearance Reinvestigation?

A security clearance reinvestigation is a formal review of a clearance holder’s background, conducted for anyone who requires access to classified information. The purpose is to determine whether the individual maintains continued eligibility for access to classified national security information. Traditionally, these reinvestigations occurred at fixed intervals: every five years for a Top Secret clearance, and every ten years for a Secret clearance.

The process determines whether the individual continues to meet federal standards for access to classified material. If concerning behavior or new relevant information has emerged since the last investigation, the reinvestigation process may explore those issues.

How Often Are Reinvestigations Required?

Under previous policy, federal employees and industrial personnel could expect a reinvestigation on a regular schedule, depending on their clearance level. However, this model has been changing. The federal government has been moving toward a dynamic monitoring model with the expansion of Continuous Vetting (CV): an automated, ongoing evaluation system.

CV is intended to replace scheduled reinvestigations, but individuals are still reviewed when security issues are flagged. After scheduled reinvestigations have been completely phased out, security clearance reinvestigations will remain a tool available to federal agencies.

Common Triggers for a Reinvestigation

Reinvestigations can be triggered in predictable or unexpected ways. Common triggers include:

• Alerts under CE: Automated checks of financial, criminal, or foreign travel records may raise red flags, prompting a deeper review.
• Criminal charges or investigations: Even if charges are dropped or dismissed, the underlying conduct may still raise concerns under the National Security Adjudicative Guidelines (SEAD-4).
• Foreign contacts or activities: Undisclosed relationships with foreign nationals or unreported foreign travel may lead to scrutiny.
• Financial issues: Delinquent debts, bankruptcies, or other financial instability may suggest susceptibility to bribery.
• Job transitions or contract changes: A move to a new agency, particularly one with different clearance standards, may require a fresh background check—even if your existing clearance is still “in scope.”
• Inaccurate or outdated information on previous SF-86 forms: A discrepancy may trigger a new electronic questionnaire or a follow-up by a background investigator. Intentionally falsified or withheld information is a very serious Guideline-E violation: often far more damning than the hidden information itself.

Some individuals are reinvestigated simply because of agency policy, backlog management, and randomized reviews.

Reporting Requirements and Self-Disclosure

Every clearance holder has a duty to report certain events to their security office. These include but are not limited to: arrests, drug use, changes in marital status, foreign travel or contacts, and significant financial events.

Proactive disclosure can significantly reduce the negative impact of a potential security issue. Failure to self-report will almost assuredly result in a far less favorable decision than voluntary disclosure. It behooves holders of security clearances to be as transparent as possible at all times.

What Happens During the Reinvestigation Process?

A reinvestigation typically begins with the submission of an updated Personnel Vetting Questionnaire (PVQ), formerly known as Standard Form 86 (SF 86). This form provides current information about the clearance holder’s background, and serves as the basis for  renewed review. Investigators examine developments since the last investigation, including financial issues, criminal history, foreign contacts, and employment conduct.

In some cases, a background investigator may contact the individual for a follow-up interview or request clarification on specific details. Investigators may also speak with colleagues, supervisors, or other references to assess the individual’s continued suitability. Depending on the situation, the process can involve in-person meetings or secure digital communication.

Derogatory findings are forwarded for adjudication. Depending on the strength of the mitigating information provided in the PVQ, this may either result favorably or unfavorably with a notice of intent to suspend or revoke clearance eligibility.

Consequences of Failing a Reinvestigation

A failed reinvestigation can carry significant consequences, like suspension or revocation of clearance. Losing clearance will directly impact your current role and limit future employment options: both federal and private.

Clearance holders have the right to appeal any unfavorable decision. However, the appeals process can take months, if not years, and involves substantial legal and procedural hurdles. In the meantime, your ability to perform your job fully will be compromised.

How an Attorney Can Help You Prepare

Security clearance reinvestigations might raise concerns that are difficult to mitigate without a working knowledge of the adjudication process and relevant case law. A security clearance attorney can guide you through your PVQ to ensure accuracy, consistency, and completeness. When prudent, they can help you preemptively address red flags before they escalate.

If you’re facing issues like financial trouble, legal charges, or foreign contacts, legal counsel can advise you on what to disclose and how to document mitigating circumstances. In many cases, presenting context early in the process is critical for a favorable outcome. Guideline E, “Personal Conduct,” requires you to disclose requested information fully and frankly at every stage of the adjudicative process.

An attorney can also help you prepare for interviews with investigators, and guide you through follow-up inquiries. If you are issued a Notice of intent to suspend, revoke, or deny your security clearance, they can represent you during appeals and assist with written responses to protect your eligibility. Early legal guidance helps safeguard your access to classified information and protect your career.

Final Thoughts on Staying Clearance-Eligible

For clearance holders, whether you are subject to traditional periodic reinvestigations or monitored under continuous evaluation, your conduct matters long after your clearance is granted. Any activity that raises concerns under the adjudicative guidelines can put your clearance at risk.

Maintaining your clearance means demonstrating the integrity, responsibility, and transparency expected of those trusted with protecting national security information.

Tully Rinckey attorneys understand that issues involving security clearances can be challenging, and they will handle your matter with the attention and tact it deserves. If you have additional questions, our team of dedicated security clearance attorneys is available to assist you today. Please call 8885294543, or schedule a consultation online.

Heather Tenney, Esq., LL.M. is a Partner in Tully Rinckey PLLC’s military law, federal employment, and national security law practice groups. She currently serves as the primary attorney for consultation in these areas. Heather brought her skills as an advocate and negotiator to Tully Rinckey after honorably serving with the US Army’s JAG Corps, and the results speak for themselves. At the firm, she focuses on military law; federal employment, EEO and discrimination litigation; disciplinary investigation and MSPB litigation, disability retirement, and national security clearance representation. Heather’s representation in national security and security clearance cases range from high-level military officers to covert operation officers of the CIA, NRO, FBI, DIA and a range of other intelligence agencies. Heather currently serves as Treasurer for the National Security Lawyers Association (NSLA). In 2025 Heather received the Lawdragon 500 Leading Civil Rights & Plaintiff Employment Lawyers award.