I’m currently in the later stages of interviews for a federal contractor role and may be close to receiving an offer that would require a Tier 2 / Public Trust background investigation. As part of preparing for that process, I had a few general questions about how these reviews are typically conducted.
For individuals who have held a long-term primary W-2 position and, at different points, also worked additional W-2 or 1099 roles in unrelated industries, how do investigators generally view situations where work periods may have overlapped?
In these types of scenarios, the work was actually performed, income was fully reported and taxed, time records were not falsified, there were no conflicts of interest, and no employer ever raised concerns or alleged misconduct.
From a definitions and standards perspective:
How is “double dipping” defined in the context of Public Trust reviews?
Is overlapping employment itself a concern, or is the focus primarily on falsified time, false claims, or misuse of funds?
What factors do investigators typically look for when determining whether overlapping work presents an issue?
I also wanted to better understand investigative scope and information handling. Are Public Trust investigations generally limited to assessing suitability and trustworthiness for the role, or do they involve broader inter-agency referrals for matters outside suitability that do not involve criminal activity?
More broadly, how is information from a Public Trust investigation typically shared or limited across agencies, and what types of issues would normally warrant referral beyond the employing agency?
I’m asking from a general process and policy standpoint to better understand how these reviews work as I prepare for a potential Public Trust process, rather than in reference to any specific case.
Double dipping itself is not an issue unless it resulted in a violation of company policy or a breach of a non-disclosure agreement or proprietary information . Investigators gather all relevant facts and include them in their report. It is an adjudicator who sees all of the information in the completed investigation and reviews it. If as you say, all work was performed as required and reported as income then it is not a problem. Agencies have no reason share investigative information unless there is an adverse determination resulting in a flag put in the system of record. In that case you would be given a chance to refute or provide mitigating factors.
Quick follow-up on secondary employment for Tier 2 Public Trust:
Many hold part-time/contract roles alongside full-time jobs, often with paid availability (on-call/bench time). Total time can appear high or overlap even without employer awareness between roles.
If work was completed, income reported, no conflicts/misuse of info, and no policy required disclosure of secondary employment, would this typically raise suitability concerns?
Key focus: lawful per-role employment and no falsified records/allegations, rather than reconstructing hours? Asking from a policy perspective on modern work patterns vs. fraud.
Thank you for the explanations so far. I also noticed a comment in a related thread stating that billing the same time for multiple employers would automatically constitute time fraud.
I am not sure exactly what the agreements specify. They mention “regular hours,” but is that by default interpreted as a standard 9‑5 schedule, or can consulting, on-call, or availability-based roles be considered differently? Occasionally, 1–3 hours here and there may have overlapped between roles.
From a policy and investigative standpoint, is “time fraud” generally understood to apply specifically to situations where an individual billed time in violation of written company policy or contractual terms (such as falsified timecards or exclusive-hours roles), as opposed to arrangements where billing is permitted regardless of task volume and no exclusivity is defined?
It sounds like you probably already know the answer and are looking for an escape clause. No one on this site will be able to tell you what the outcome will be because each investigation is adjudicated on its’ own merits based on the information in it.