3 Tips to Avoid Scope-Creep in Workplace Investigations

How you handle unrelated information uncovered in interviews can affect the outcome of your internal investigation.

Posted by Dawn Lomer in Bullying, Code of Conduct, Corporate Security, Discrimination, Employment Law, Government Program Fraud, Harassment, Healthcare Fraud, Human Resources, SIU & OIG on September 22nd, 2011

Staying focused when conducting workplace investigations is tough, but when unrelated issues are uncovered, keeping on the right track becomes even more challenging. To make matters worse, there may be multiple issues uncovered of varying seriousness, sometimes affecting different stakeholders and business units. A workplace harassment investigation may uncover evidence of fraud. When this type of priority conflict occurs, it’s tempting for an investigator to follow up on all streams of information, to get a full picture of the subject being investigated. But that’s exactly what he or she shouldn’t do.

“It’s a thing that I call scope creep,” says Sheryl Vacca, Senior Vice President and Chief Compliance and Audit Officer at the University of California. “The problem is that there’s a single issue, let’s just say improper allocation of funds, and while they’re looking at improper allocation of funds, something might come up that would be related but isn’t your focus. Maybe harassment in that particular unit,” she explains.

1. Don’t Investigate Everything at Once

“The worst thing that an investigator can do is to take all of these things that come up and start to investigate them all, rather than the initial allegation,” says Vacca.

She says it’s important that investigators understand what to do with new issues when they arise during the course of an investigation and this often involves triaging them separately.

“If it makes sense to add it to what’s happening, we’ll notify management and make sure everyone has the same expectation… we won’t start going out in this sea of issues where nobody knows what’s happening, why we went there or how this came up.”

Vacca says that outside issues needed to be decided on one-by-one, asking the following questions: Should I investigate this? Is this something management just needs to know? What do we need to do with this?

2. Prioritize Parallel Paths

In order to avoid duplicating work, an investigator may benefit from conducting investigations in a particular order.

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“Sometimes with HR issues it may very well be that there’s a parallel path that looks just like the one you’re taking in an investigation,” says Vacca.

“So we may say no [to investigation another issue] because this investigation is already started and we want to get it finished. Or we may say no, this parallel path should come first, then we’ll come behind it and we’ll leverage the information we received from the parallel path, and not duplicate,” she says.

 3. Never Stop What You’ve Started

Whichever path the investigation follows, there’s one thing Vacca is clear on:

“We never drop an investigation. We will always take an investigation to the point of substantiated or not substantiated,” she says.

Sometimes this means giving more importance to one investigation and using the information uncovered to strengthen another. Sometimes it means finishing the investigation under way before moving on to tackle the next issue.

“You have to make these decisions all the time,” says Vacca. “There’s no one way that you do anything. That’s the problem.”

 


Dawn Lomer
Dawn Lomer

Managing Editor

Dawn Lomer is the managing editor at i-Sight Software and a Certified Fraud Examiner (CFE). She writes about topics related to workplace investigations, ethics and compliance, data security and e-discovery, and hosts i-Sight webinars.