Positions Subject to Enhanced Suitability


Effective Date: Expiration Date: Chapters:
Feb. 24, 2021 July 20, 2021 4  


The District government maintains a highly qualified and diverse workforce comprised of suitable individuals of moral character and dedication who carry out government business in a manner that honors the public trust. These employees are committed to promoting the safety and security of District personnel, residents, visitors, and government property.

To this end, we assess the suitability, character, reputation, and fitness for duty, of each applicant, appointee, volunteer, and employee through various mechanisms including uniform background checks and drug and alcohol testing, as deemed necessary. Our enhanced suitability program supports flexible human resources administration, government accountability, individual privacy, and other constitutionally protected rights.

This issuance describes enhanced suitability screening requirements for safety, protection, and security sensitive positions as indicated in Chapter 4, Suitability, of the D.C. personnel regulations.   

NOTE: This issuance updates the listing of positions designated as safety, protection, and security sensitive. The updated designation listing may be accessed by clicking here. This issuance supersedes Issuances I-2017-4-38, 2019-4, 2019-15, and 2019-19, dated October 21, 2017, January 24, 2019, November 14, 2019, and December 16, 2019, respectively.

Covered Positions

Appointees, volunteers, and employees are subject to enhanced suitability screenings based on their position designations, which are determined by their job duties. If dictated by their duties, a position may be designated as one of the following:

Safety Sensitive: Positions in which it is reasonably foreseeable that, if the employee performs the position’s routine duties while under the influence of drugs or alcohol, the employee could suffer a lapse of attention or other temporary deficit that would likely cause actual, immediate, and serious bodily injury or loss of life to self or others.

Protection Sensitive: Positions that are not safety sensitive positions, but that include duties or responsibilities that involve caring for patients or other vulnerable persons.

Security Sensitive: Positions of special trust that may reasonably be expected to affect the access to or control of activities, systems, or resources that are subject to misappropriation, malicious mischief, damage, or loss or impairment of communications or control.  

ENHANCED SUITABILITY SCREENING TYPES Safety Sensitive Protection Sensitive Security Sensitive
Criminal background check (pre-employment and periodic) X X X
Traffic record check (as applicable; biennial) X X X
Pre-employment drug and alcohol test X X  
Random drug and alcohol test X     
Return-to-duty or follow-up drug and alcohol test X X    
Consumer credit check (Pre-employment and finance related positions only)


Reasonable suspicion and post-incident and accident drug and alcohol tests are not listed here as they apply to all District employees, not only to employees in positions subject to enhanced suitability.

For a complete list of covered positions, click here

Pre-Employment Suitability Screening

All safety, protection, and security sensitive appointees, including current employees newly appointed to such positions through details, reassignments, and promotions, must undergo the appropriate, required pre-employment suitability screenings upon receipt of a conditional offer of appointment.  

Credit History Screening

Appointees to security sensitive jobs that include access to or control over financial assets or instruments must undergo a pre-employment credit history screening.

Criminal Background Screening

All safety, protection, and security sensitive appointees must successfully undergo a criminal background screening.

Drug and Alcohol Screening

All safety and protection sensitive appointees must undergo a pre-employment drug and alcohol screening. Except for cannabis (marijuana) as described below, a positive drug or alcohol test result disqualifies safety and protection sensitive appointees from further employment in a safety or protection sensitive job for one year.

Appointees to safety sensitive positions are screened for marijuana usage. Unless otherwise authorized by DCHR to address immediate recruitment needs, if a safety sensitive appointee tests positive for only marijuana and was not in possession of or showed signs of being under the influence of marijuana at the time of testing, the agency must give the appointee a second opportunity to drug test at least two weeks later. Failing a second drug test will result in disqualification from employment in a District safety sensitive position for one year. Positive results on the first test for any other controlled substances will result in disqualification.

Protection sensitive positions are not screened for marijuana.

NOTE: Agencies may not disqualify appointees to safety sensitive positions simply because they are enrolled in a medical marijuana program. However, even if an appointee or employee is enrolled in such a program, they may not test positive for marijuana on any drug test.

Traffic Record Checks

Appointees to a safety, protection, or security sensitive position that includes driving as part of their routine government duties must undergo a traffic records check every two years.

Ongoing Suitability Assessment

The District government must reassess safety, protection, and security sensitive employees’ suitability on a periodic basis.   

Criminal Background Screening

Employees in safety and protection sensitive positions must undergo a criminal background check at least once every two years. Employees in security sensitive positions must undergo a criminal background check at least once every four years. Volunteers and employees subject to criminal background checks must notify their supervisor and the personnel authority within seven days if they are arrested or charged with a criminal offense.

Drug and Alcohol Screening

Employees in safety sensitive positions are subject to random drug and alcohol screening and can expect to be drug tested at any time.

Traffic Record Screening

Employees who occupy a safety, protection, or security sensitive position and drive as part of their routine government duties must undergo a traffic records check every two years.


Appointees should be informed of their sensitivity designation in any vacancy announcement, appointment offer, or position description. Additionally, for safety sensitive employees, agencies must provide each employee a copy of the drug policy on an annual basis. Safety sensitive employees are required to acknowledge the drug policy annually through PeopleSoft.

Pursuant to the Medical Marijuana Program Patient Employment Protection Amendment Act of 2020, agencies shall provide notice to safety sensitive employees of their rights to request a written explanation justifying the designation of their position, to request a reasonable accommodation, and to appeal their designation under certain circumstances.

An employee may appeal the designation of his or her position as safety, protection, or security sensitive. Any such appeal must be in writing and filed with the program administrator or personnel authority, as appropriate.  

Enhanced Suitability Screening Forms and Handling

When necessary, agencies will provide appointees and employees with the forms and instructions to undergo required suitability screenings. Most agencies only use forms approved by the D.C. Department of Human Resources. These forms are available online at dchr.in.dc.gov.

DCHR will retain any forms it receives related to enhanced suitability screening. Supporting documents and screening results will be tracked in Truescreen and an internal encrypted database. Agencies will be provided access to Truescreen to review status updates for ongoing enhanced suitability screenings.

For purposes of audits and any administrative or judicial reviews, agencies must store any notices related to a final suitability determination in a confidential folder separate from the Official Personnel File (OPF). 

Fire & Emergency Medical Services Department

For safety sensitive employees within the Fire and Emergency Medical Services Department (FEMS), the Chief serves as the program administrator for purposes of drug and alcohol testing. 


All District supervisors and managers are required to undergo reasonable suspicion training to learn techniques for drug and alcohol abuse detection and recognition, documentation, and referral. Agencies are responsible for ensuring their staff undergo this training. At a minimum, supervisors and managers should receive this training at least once every two years. 

Collective Bargaining Agreements

DCHR, or the personnel authority, will review the union status of each employee prior to administering enhanced suitability screening. For unionized employees, any enhanced screening performed will be conducted in accordance with the appropriate collective bargaining agreement (CBA). If the procedures in the CBA differ from those outlined in Chapter 4, Suitability, of the D.C. personnel regulations, the CBA shall control with respect to the specific conflict.  


The provisions of this issuance apply to those District government agencies which are subordinate to the Mayor’s personnel authority. Other personnel authorities or independent agencies may adopt any or all of these procedures to provide guidance to employees under their respective jurisdictions. 

Additional Information

For additional information on the D.C. Department of Human Resources’ suitability program, please refer to the Chapter 4 of the electronic Personnel Manual (e-DPM), Suitability.

Agencies and unions with questions about the provisions of this issuance may be directed to the Policy and Compliance Administration, DCHR, at (202) 442-9700 or [email protected]. Employees who have questions about the suitability program should contact their agency Human Resources office. 

Issued by Director Ventris C. Gibson, D.C. Department of Human Resources on Feb. 25, 2021, 8:42 a.m.