The eApp was implemented on 1 October 2023 as the primary system to replace the eQIP for completing the SF-86 in federal employment. The new portal has brought some useful features like autosave, timeline continuity, definitions/acronym explanations, and address verification. Additionally, the system offers intuitive question branching, such that applicants are only directed to questions relevant to his/her history based on previous responses, which can be a time-saver. There are some significant drawbacks with the new system, however. The lack of optional comment availability and the removal of the continuation space at the end severely limit an applicant’s ability to provide mitigating explanations to accompany potentially derogatory disclosures. While some sections do offer an optional comment space, it is only made available if the applicant has responded “Yes” to a question. Oftentimes, an applicant can properly respond “No” to a question, but will want to offer some context or clarity for the sake of transparency, and the eApp does not offer that opportunity to explain as the eQIP did. Further, these optional comments are limited by the number of characters allowed in that explanation and may be insufficient to explain a complex disclosure. Practically speaking, the eApp system makes it much more difficult to save a draft than the eQIP, so it is now more difficult for an applicant to review his/her responses before submission.
Justyn Ann Baxley is a Partner with JAG Defense. Her practice primarily focuses on security clearance law and administrative law. As a security clearance lawyer, Ms. Baxley has represented hundreds of individuals in security clearance adjudications across virtually every federal agency, to include the Department of Defense, the Department of Homeland Security, the Department of Energy, the National Security Agency, NASA, and others.
