A common concern for individuals undergoing a federal background investigation is the case of the elusive former employer. The applicant simply cannot provide substantive information about an employment during the course of an investigation, which creates a gap in the applicant’s profile.
This situation often arises in three different scenarios: the former employer relocated; the former co-workers have since vacated the employment; or the employer simply no longer exists. The preferred approach to each situation varies, so I will address each scenario separately:
The relocation of a former employer should not present many problems for an applicant. Often times the employer maintains the same phone number and website, allowing for the applicant to easily obtain the employer’s new contact information. Depending on how far the employer moved to relocate, there is a likelihood that at least some of the applicant’s former co-workers remain.
Once the applicant obtains the new contact information, the applicant must determine whether to list the new address on the SF-86 or the address at which he or she worked. The best practice is to list the new address. This will orient the investigator to the appropriate address at which former co-workers and personnel records are most likely located. The applicant should place a small disclaimer in the comments section indicating the location at which he or she actually worked, but explaining that the employer has since moved.
CO-WORKERS HAVE RELOCATED
The mass employee exodus — be it the product of employer layoffs or the passage of time — can be especially troublesome for an applicant. In this scenario, no co-workers remain at a former employment, and the applicant is unsure who to list on the SF-86.
To combat this quandary, the applicant should start by providing the investigator what he or she does know. So if the applicant maintains updated contact information for former co-workers, that applicant should ensure his or her investigator receives that information by listing it on the SF-86 and providing it during the personal interview.
Alternatively, if the applicant can provide, for instance, reliable contact information for at least one former co-worker along with a list of names of other former co-workers, it’s a good start. The reliable source provided by the applicant may be the channel through which the investigator can track down the other co-workers whose whereabouts were otherwise unknown.
THE EMPLOYMENT NO LONGER EXISTS
If it appears as though an employment no longer exists, the applicant should take some precautionary measures to verify this is actually the case. It’s not uncommon for an employer to rebrand and change its name or for another entity to acquire an employer, whereby the employer assumes the name of the acquiring entity.
Once the applicant unequivocally establishes the non-existence of his or her former employer, the applicant should combine the processes outlined throughout this post.
- First, the applicant should compile all known contact information for former co-workers and provide this information to the investigator. In the event that this information is not available, the applicant should provide names of those people who can at least corroborate the activity or who had some peripheral relation to the activity (for example, someone who worked for another employer at the same location)
- Second, the applicant should list the last known address and phone number for the employer and supervisor on the SF-86. The investigator still needs to personally verify the employment no longer exists, and not simply take the applicant’s word for it.
- Finally, the applicant should disclaim the fact that the employment no longer exists in the comments section of the SF-86.
A SHARED BURDEN
One final word of advice: there is an implicit understanding that, on occasion, an investigator simply might not be able to verify a former employment. That understanding is conditioned upon the premise that both the applicant and the investigator have satisfied their respective obligations in reaching a common goal.
Federal background investigations are unique in that they are consensual. As such, applicants have a duty to disclose all requested employment information reasonably available to them. But that does not discharge an investigator’s corresponding duty to exhaust all reasonable efforts to verify past employer information.