Psychological Conditions and Security Clearances

Mental health is a security concern because it influences how a person perceives the world, makes decisions and manages stress. The fact that an individual has had, or continues to have, an emotional, mental or psychological condition does not, by itself, preclude granting access to classified information. The issue is whether the individual's condition causes, or may cause, poor judgment or unreliable, untrustworthy or dysfunctional behavior.  

Many people, perhaps most people, experience some form of stress that threatens their self-image at some time in their lives. They experience failure to compete effectively with their peers; perceive injustice at the hands of a supervisor or employing organization; are terminated from a job under circumstances that prompt resentment; feel rejected or betrayed by a spouse; confront serious financial or medical problems; or are tempted by a seemingly easy opportunity for illegal monetary gain.

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Emotionally stable and well-adjusted individuals generally respond to these experiences in positive ways: by learning from them, adjusting their expectations, working harder or sticking with their core values. Individuals who are unstable or poorly adjusted, have a significant character weakness or suffer from mental illness may react in ways that are self-destructive, counterproductive or illegal. They may harm the organization by actions that run the gamut from absenteeism to self-serving decisions, theft, fraud, sabotage or espionage.

Potentially Disqualifying Conditions

Extract from the guideline:

(a) behavior that casts doubt on an individual's judgment, reliability, or trustworthiness that is not covered under any other guideline, including but not limited to emotionally unstable, irresponsible, dysfunctional, violent, paranoid, or bizarre behavior;

(b) an opinion by a duly qualified mental health professional that the individual has a condition not covered under any other guideline that may impair judgment, reliability, or trustworthiness;

(c) the individual has failed to follow treatment advice related to a diagnosed emotional, mental, or personality condition, e.g., failure to take prescribed medication.

The potentially disqualifying conditions are quite general. Some of the more specific circumstances that may be disqualifying under these guidelines include the following:

• History of violent or abusive behavior toward spouse, children, elders, or work associates.
• Behaviors such as compulsive gambling, compulsive sexual behavior [and] compulsive lying. A behavior is compulsive when it is beyond a person's control, i.e., the person continues to engage in it despite adverse medical, legal, social, family or work consequences.
• Abnormal preoccupation with or irresponsible use of weapons.
• Observed symptoms of a possible emotional or mental problem. Symptoms are listed in the section entitled "Clinical Indicators of Potential Emotional or Mental Problem."
• Taking a prescription drug that has side effects of a potential security concern. See the section entitled "Controlling Disorders with Drugs."
• Refusal to take medical/psychiatric tests when so directed by competent authority.

The potential security significance of a psychological condition depends upon how it affects the subject's judgment, reliability or trustworthiness, its severity (intensity and duration of symptoms), whether there has been appropriate treatment or whether the condition is typically responsive to treatment, and the judgment of a qualified mental health consultant about possible recurrence and what else might happen in the future.

Clinical Indicators of a Potential Emotional or Mental Problem

"The Diagnostic and Statistical Manual of Mental Disorders," published by the American Psychiatric Association, describes hundreds of mental disorders. Important categories of disorders include anxiety disorders, such as panic disorder, generalized anxiety disorder and phobias; mood disorders, such as depression or bipolar disorders; cognitive disorders, such as dementia; personality disorders, such as antisocial, paranoid, schizotypal or borderline personality disorder; and schizophrenia or other psychotic disorders.

As stated earlier, the existence of a psychological condition does not preclude the granting of a security clearance. Some conditions are unrelated to security issues, and others can be mitigated by ongoing treatment or other factors. If indicators of a psychological condition are reported, additional inquiries should be made and consultation with a qualified mental health professional should be considered.

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The following list provides examples of some of the most commonly observed clinical indicators of a possible mental health problem. In general, clinical indicators of the greatest concern are those that are disruptive to an individual's work or social functioning and/or activities of daily living. These indicators are sometimes identified during investigative interviews with supervisors, co-workers, friends and neighbors.

• Repetitive worrying or recurrent or persistent thoughts that cause anxiety or distress; recurrent nervousness, restlessness or hyperactivity that impairs function or performance.
• Incidents of explosive anger or sudden outbursts of temper; failure to resist anger or aggressive impulses that result in serious acts of assault or destruction of property.
• State of sadness or depressed mood that has advanced to the point of being disruptive to functioning.
• Intense and unstable (dysfunctional) personal relationships.
• Ongoing suspicions, without sufficient basis, that others are exploiting, harming or deceiving him or her; talk of being watched or followed.
• Grossly disorganized behavior and/or speech (e.g., dressing inappropriately, severe neglect in self-care, frequent loose association of thoughts or speech, odd use of words or language structure).
• Delusions or false beliefs based on incorrect inferences about reality that are firmly sustained despite evidence to the contrary and lack of corroboration from others.

Other Observable Behaviors

There are a number of other observable behaviors that relate to issues under Personal Conduct as well as the Psychological Conditions guideline. These behaviors are often found in persons who commit espionage or other white-collar crimes. They are also found to some degree in many law-abiding and successful individuals, so they are not disqualifying by themselves. However, they can and should be part of a whole-person evaluation when there is other adverse information about the individual.

• Pattern of lying, misrepresentation, gross exaggeration or failure to follow through on promises or commitments.
• Pattern of doing whatever feels good at the moment, without regard for duties or obligations, or without regard for the long-term consequences for self or others.
• Stretching the limits to see what one can get away with, taking pleasure in beating the system and not getting caught, or cutting corners to achieve personal objectives.
• Treating other people as objects to be manipulated for the benefit of one's own self-interest or to indulge one's own desires.
• Overreaction to criticism, responding with anger even to constructive and well-intentioned criticism.
• Vindictive. Seeks revenge for any real or imagined wrongs.
• Feels so smart or so important that the rules, which were made for ordinary people, do not apply.
• Taking risks just for the thrill of it.
• Inability to form personal relationships; limited capacity to express either positive or negative emotions toward others.

Counseling and Treatment

Executive Order 12968, dated Aug. 4, 1995, states that "no negative inference concerning eligibility for access to classified information may be made solely on the basis of mental health counseling." The fact that an individual has sought treatment or counseling for a mental health problem does not suggest that the individual's problem is more serious than one who has not received counseling. When self-initiated, treatment is often a favorable indication that the subject recognizes the problem and is taking care of it. This voluntary action is positive evidence of reliability and a willingness to fulfill personnel security responsibilities. When investigative results are reviewed to make a security clearance decision, the fact that the individual voluntarily sought professional help is a significant positive factor in the decision.

The SF-86 security questionnaire filled out by all security clearance applicants requires reporting any mental health counseling or treatment received during the previous seven years unless it is "strictly for a marital, family, or grief issue not related to violence by you, or strictly related to adjustments from service in a military combat environment."

Military and civilian personnel on tours in combat areas, such as Iraq and Afghanistan, have been subjected to extreme stress that often requires some form of mental health counseling, and this does not need to be reported on the security questionnaire. DoD Instruction 6490.06, dated April 21, 2009, specifies responsibilities and procedures for implementing DoD policy to:

a. Promote a culture that encourages delivery and receipt of counseling.
b. Eliminate barriers to and the negative stigma associated with seeking counseling support.
c. Empower leaders to advocate for those in their charge to receive counseling.
d. Provide easy access to a continuum of counseling support to include prevention, early intervention and treatment to enhance coping and build resilience.
e. View counseling support as a force multiplier enhancing military and family readiness.

The security questionnaire exempts reporting of marital or family counseling that does not involve the use of violence. However, life is not that simple. Marital problems may be a security concern if they are caused by alcohol, drugs, financial irresponsibility, certain types of sexual behavior or any other behavior that would be of concern independent of the marital issues. The adjudicator needs to know if the marital or family problem was related to any form of physical abuse, alcohol abuse, drug use, financial irresponsibility, compulsive gambling, irresponsible use of weapons or any other potentially disqualifying issue. The adjudicator also needs to know if family or marital counseling resulted in (1) prescribed medication that affects mental or emotional functions, (2) referral for additional evaluation or treatment, or (3) a diagnosis of any mental or emotional condition.

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Many other forms of short-term counseling (six months or less) have no relevance to security. This includes counseling for adolescent or school adjustment problems during the previous seven years, grief or bereavement counseling, self-improvement counseling or counseling for victims of rape, incest or other trauma.

Using Professional Diagnoses

A duly qualified mental health professional associated with the adjudicative facility and experienced in making personnel security judgments plays an important role in advising the adjudicator about the significance of an individual's behavior, how it relates to security concerns, amenability to treatment or counseling, and the prognosis for future behavior. However, it remains the adjudicator's responsibility to judge, based on all the available information, whether an individual's actions meet appropriate standards of reliability, trustworthiness and good judgment.

As stated in the guideline, formal diagnosis of an emotional, mental or personality disorder is not required for an adverse decision. This is because:

• Some behaviors that are disqualifying do not meet all the criteria for diagnosis of a disorder.
• Information for a formal diagnosis may not be available if the individual withholds information for fear it would put his or her security clearance at risk. The mental health professional can make a diagnosis only on the basis of the incomplete information disclosed by the individual, or what information the mental health professional has been provided from the investigation.
• A private mental health professional is serving the best interests of his or her client and may not understand the government's security requirements. Private mental health professionals sometimes provide a relatively benign diagnosis because they do not want their clients to lose their job, or because they are concerned about legal liability if their clients lose their job because of the diagnosis.
• There is disagreement among mental health professionals on what constitutes a disorder and, in many cases, about when behavior meets the threshold for diagnosis of a specific disorder.

Conversely, the diagnosis of an emotional, mental, or personality disorder does not necessarily mean an individual actually has a security-relevant problem. This is because:

• Not all diagnosed disorders are a security concern.
• The mental health provider may list a diagnosis only to ensure the visit will be covered by medical insurance.
• Some mental health providers give a diagnosis because the patient would be dissatisfied if the doctor failed to provide a "diagnosis" for whatever the patient perceived as a problem. Some persons seek regular psychiatric or psychological counseling for minor problems.
• Medication that is being taken regularly keeps the condition under control.

Mitigating Conditions

Extract from the guideline:

(a) the identified condition is readily controllable with treatment, and the individual has demonstrated ongoing and consistent compliance with the treatment plan;

(b) the individual has voluntarily entered a counseling or treatment program for a condition that is amenable to treatment, and the individual is currently receiving counseling or treatment with a favorable prognosis by a duly qualified mental health professional;

(c) recent opinion by a duly qualified mental health professional employed by, or acceptable to and approved by the U.S. Government that an individual's previous condition is under control or in remission, and has a low probability of recurrence or exacerbation;

(d) the past emotional instability was a temporary condition (e.g., one caused by death, illness, or marital breakup), the situation has been resolved, and the individual no longer shows indications of emotional instability;

(e) there is no indication of a current problem.

The following points elaborate on the above potentially disqualifying conditions:

• Controllable with treatment: Depression is perhaps the most common example of a condition that is controllable with treatment. The required period of compliance may depend upon the severity of the symptoms that would be expected if the individual failed to take the prescribed medication. Long-term continuation of the medication must be medically practical and must be expected to preclude recurrence of any condition that may affect judgment or reliability.
• Voluntary counseling or treatment: The individual has voluntarily entered a counseling or treatment program for a condition that is amenable to treatment, and the individual is currently receiving counseling or treatment with a favorable prognosis by a duly qualified mental health professional approved by or acceptable to the U.S. Government (i.e., the adjudicative facility). The fact that an individual has entered treatment voluntarily, without it being required by a supervisor or a court, is a definite plus. It shows that an individual is aware of the problem and trying to deal with it. This mitigation would apply only to an individual who already has a clearance, not to a new applicant. An employer has an obligation to help an employee who develops a problem while on the job, but no such obligation to hire a new employee who already has a mental health problem.
• Professional opinion: This mitigating condition is used when a duly qualified mental health professional determines that a known previous condition is now under control or in remission and has a low probability of recurrence or becoming worse.
• Temporary condition: Traumatic personal circumstances often cause a temporary condition that requires some counseling or treatment but is not a security concern. If such a condition has not been resolved within six months, however, this suggests the possibility of a longer-term condition.
• No current problem:  This mitigating condition is used when the adjudicator or a duly qualified mental health professional determines that the reported information is not really a security concern.

Controlling Disorders with Drugs

Many psychological conditions are the result of imbalances of brain chemicals called neurotransmitters. These imbalances can produce the observed symptoms and changes in behavior and are often treated with medication. In most cases, the source of the imbalance is both genetic and environmental, and often both medication and therapy are useful for treating the condition.

There are many different types of psychiatric medications, and the effects and side effects of the medications vary a great deal. Important questions to be considered when adjudicating a psychological condition being treated by medication include: 

• What symptoms caused the doctor to prescribe medication or caused the subject to start taking medication on his or her own? 
• How do these symptoms affect the subject's reliability and judgment? 
• How does the medication affect the subject's reliability and judgment? 
• What happens if the subject stops taking medication? 
• Has the subject ever failed or refused to take the medication?

Some psychiatric medications can have side effects that are relevant to security concerns and may require careful monitoring, particularly since different individuals react to psychiatric medication in different ways. The field of psychopharmacology is highly technical and is evolving as a result of ongoing and new research. Adjudicators should rely in each case on the input of their qualified mental health consultant.

Footnotes

1. List provided by Dr. Leissa Nelson, PERSEREC.

2. Blitzer, W. (1989). Territory of Lies: The Rise, Fall, and Betrayal of Jonathan Jay Pollard. New York: Harper & Row.

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