It's hand-holding time

Employees facing background checks will need reassurance and training to help them adjust to the new smart cards

HSPD-12 Facts

Editor's note: This story was updated at 4 p.m. Aug. 21, 2007. Please go to Corrections & Clarifications to see what has changed.

Wesley Carpenter has been racking up frequent-flier miles. As director of the Environmental Protection Agency’s Security Management Division, Carpenter has been crisscrossing the country to assist the agency’s offices with implementing Homeland Security Presidential Directive 12, the mandated identity verification program. In the course of a few days in June, he visited field offices in San Francisco, Seattle and Denver.

“We are basically making sure that the employees in these facilities who are responsible for security clearly understand what they are going to need to do when it comes to identity proofing and identity-card issuance,” Carpenter said in a phone interview from Denver.

But before EPA and other federal agencies can benefit from the new credentials, they must assemble the infrastructure for issuing cards to about 2 million employees and 5 million contractors. In addition, they are working with the Office of Personnel Management to complete background checks on people receiving the cards, and they are training employees and contractors in their use.

As the October 2008 final deadline for HSPD-12 approaches, agencies also must contend with employee unions’ growing concerns about privacy. Officials of one union say they may file a complaint alleging unfair labor practices with the Federal Labor Relations Authority.

Despite those concerns, agency officials say they have no choice but to move forward with their preparations for issuing cards. EPA chose to use its own resources to implement HSPD-12 internally at its Washington headquarters and regional offices. For its nationwide field offices, the agency will rely on the General Services Administration’s HSPD-12 Managed Services Office and its contractor, EDS.

EPA employees will receive intranet-based training in how to use the new cards, and GSA will also offer training.

“When an enrollment station is installed — and if the operator is a local agency contractor or government employee — the installer will install the machine and spend one day in hands-on training for the operator,” said Mike Butler, program manager at the HSPD-12 Managed Services Office.

Butler said GSA has established online training tailored to employees’ roles in the HSPD-12 program. The agency is working to ensure that all employees using the shared-services provider receive online training related to their HSPD-12 roles, whether they are managers, sponsors, adjudicators, security officers, registrars, activators or employees.

Although many agencies are turning to GSA for at least some of their card needs, others have decided they can meet HSPD-12’s requirements on their own.

Brian Epley, the personal identity verification manager at the Department of Veterans Affairs, said the agency’s previous identity-management experience prepared it for issuing HSPD-12 cards to its employees. The agency has more than 1,200 facilities and will establish about 225 enrollment sites for issuing the cards.

In addition to training registrars and issuers, VA is training employees as sponsors and coordinators to expedite the HSPD-12 enrollment process. Epley said the agency is going beyond the required cybersecurity awareness and privacy training and is using online resources to teach employees how to use their HSPD-12 cards to digitally sign and encrypt e-mail messages. Epley said he hopes other agencies will use VA’s training facilities.

“We’ve leveraged existing training tools and resources, our learning management resources and the VA Learning University,” Epley said, because that approach saves money and avoids costs for the agency.

However, training is not the issue that has raised concerns among employee unions. Some union leaders and government watchdog groups say they question whether HSPD-12 will make employees more secure at work or leave them more vulnerable. Officials of GSA’s two labor unions — the National Federation of Federal Employees (NFFE) and the American Federation of Government Employees (AFGE) — say they object to the way the agency is complying with the directive’s mandated background checks.

Under HSPD-12, agencies must submit employees and long-term government contractors to background investigations conducted by OPM. Those investigations include at least the basic National Agency Check and Inquiry and a criminal history check by the FBI. Many employees and contractors will require further investigation, depending on their clearance levels.

Kathy Dillaman, OPM’s associate director of investigations, said the HSPD-12 program will generate about 100,000 to 120,000 new requests for background checks each year, and the agency should be able to handle the increase.

But some union leaders question the need for background checks on existing federal workers. NFFE Region 5 Vice President Charles Paidock said asking employees to fill out forms and investigating them after they have been working for the government for years amounts to making them reapply for their jobs.
“Employees called me up right away, and they said, ‘It’s just another method to thin the herd,’ ” he said.

Union officials say GSA did not meet its obligations to the union when the agency began implementing HSPD-12’s provisions for background investigations. They are also concerned that background checks would be used to target some employees.

A GSA spokeswoman said the agency has no choice but to conduct the investigations as mandated under the directive. Furthermore, the background checks are not meant to single out employees based on politics or ideology, Dillaman said.

“Just because someone has been in a position for a long time doesn’t mean that there may not still be a risk involved,” she said. “These are going on exactly the same track as any other background investigation that determines suitability of access to classified information.”

However, union leaders say the investigations open the door to possible discrimination. They are concerned that employees who did not receive thorough background checks 25 years ago could lose their jobs when they are scrutinized under the HSPD-12 guidelines. Labor leaders say they are also concerned about how agencies will safeguard the personal data they collect.

Following HSPD-12 guidelines, agencies identify the employees and contractors who need to be investigated, and OPM works with its contractor employees to conduct the investigations. The findings are returned to the agency for review.

OPM officials said they hold contractors to high standards. However, Jacqueline Simon, AFGE’s public policy director, said she is not convinced.

“Because mistakes inevitably are made and because of the way federal agencies have exercised such lax control, supervision and oversight over their contractors, federal employees have very understandable concerns about whether this information will be used solely for the purpose for which it’s advertised,” Simon said.

OPM said the data is safeguarded and shared only with the employee’s agency. In addition, officials who helped write the HSPD-12 specifications say the cards have built-in security and privacy safeguards.

“From the very start, we were conscious of the privacy implications of it,” said

William Burr, who worked on the implementation guidelines as manager of the National Institute of Standards and Technology’s Security Technology Group. “The basic strategy was to be very cautious about exposing [personally identifiable information] and to try not to make those issues any worse than they inherently are with any identity card.”

The HSPD-12 card has a number of features — including personal identification numbers and biometrics — to ensure security, Burr said.

“If you do the full bore, you get the three-factor authentication,” he said. Burr explained that the private key proves physical possession of the card, the biometric feature confirms identity, and employees will use their PINs to prove they have the necessary private knowledge.

Despite the program’s controversial aspects, some agency officials say they believe HSPD-12 is the right course with its mandtory background checks. “This just gives us another opportunity to make sure that our information is complete,” said Patrick Howard, chief information security officer at the Housing and Urban Development Department.

HUD is taking a hybrid approach to its HSPD-12 implementation. It is seeking GSA’s help in tailoring a training program to employees at its field offices and has made fact sheets and other training resources available on its intranet for other employees. Extensive training for HUD employees and contractors has not been necessary so far because the agency has used the cards primarily as replacements for its existing employee ID cards.

But as employees begin to use HSPD-12 cards in more advanced ways a year from now, training demands will escalate, Howard said. “It’s real important to set the expectations of the users,” he added.
Employees can appeal if denied an HSPD-12 cardFederal employees can appeal if they are denied a personal identity card under the new credentialing program, Homeland Security Presidential Directive 12. For example, guidelines published by the Commerce Department state that if employees are turned down after making their first application for an HSPD-12 card, they:

  • Will be notified and told the basis of the denial by their human resources department.
  • Can submit a letter of appeal to the human resources department, along with any information that supports their claim.
  • Will be notified about the result of the appeal.
  • Have no appellate rights if they are contractors or foreign nationals.

— Ben Bain


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