External Whistleblowing vs. Internal Whistleblowing: Explained

External vs. Internal Whistleblowers

What It Means for Your Case
If You Report Internally or Externally

Internal whistleblowing means reporting the problem inside your company, to a supervisor, HR, or the legal department. External whistleblowing means taking it outside, to a government agency, a court, or your own attorney. The difference matters: only external reporting through the right channel triggers the strongest legal protections and the chance at a reward, but it also moves fast and largely out of your control. Talk to a whistleblower attorney before you pick a path. Call (888) 713-6653 for a free, confidential review.

Have you considered blowing the whistle about conditions or practices at your place of employment?

If so, it is important that you know the laws involved and what may happen when you decide to come forward.

Whether you are an external or internal whistleblower may play a major role in what happens next. You should understand what these terms mean so that you can decide how to handle your claims.

In this short guide, you’ll learn what whistleblowing is, and how to tell the difference between internal and external whistleblowing.

You’ll learn how to decide between these two options, and how a lawyer can help you if you face retaliation for your choice.

 

 

What happens when you become a whistleblower?
State and Federal law provide for a number of protections for whistleblowers who come forward to report fraud, misconduct, and abuse. Your complaint will be investigated, internally or by an external organization like the Dept. of Justice. Your whistleblower attorney will help you manage this complex process.

What is Considered Whistleblowing?

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Whistleblowing refers to the act of reporting waste, fraud, corruption, or other misconduct and abuses.

You can report wrongdoings that occur at either public or private organizations, but not all abuses are against the law.

When the violations you’re reporting are against the law (for example; when they include fraud against government programs) the False Claims Act (FCA) may apply.

The FCA does not apply to all types of whistleblowing. Knowing the difference between external and internal whistleblowing and the protections afforded to whistleblowers who make a protected disclosure is vital to achieving a meaningful and successful resolution.


What role does the FCA play in whistleblowing cases?

The FCA imposes significant penalties against persons or companies who defraud government programs. Health care and military contracting programs are particularly susceptible to fraud, so this law encourages whistleblowers to report this fraud by offering them a reward.

The law includes a qui tam provision that allows whistleblowers to file actions on behalf of the government. If the action is successful, whistleblowers may be rewarded with a percentage of all funds that are recovered. In the past, whistleblowers have earned millions of dollars after being a part of a successful FCA case.

 

What is the Difference Between External and Internal Whistleblowing

Before you blow the whistle about any practice in your workplace, you should decide whether you are going to be an external whistleblower or an internal one. To make this decision more effectively, you should understand them both.

The following will help you understand the difference between these types of whistleblowers, and help you understand how to make a protected disclosure in each case. The path you and your attorney choose will ensure you protect yourself and help end the misconduct more effectively.

Internal vs. External Whistleblowing at a Glance
 Internal WhistleblowingExternal Whistleblowing
Where you reportInside the company (supervisor, HR, legal or compliance)Outside the company (a government agency, a court, or your own attorney)
Legal protectionProtected in many situations, but narrowerStrongest federal protections when filed through the right channel
Reward eligibilityNo reward for an internal report alone15% to 30% of the recovery in a successful qui tam case
ControlYou keep more control early, but the company may bury itMoves into the government's hands; you may lose control of timing
ConfidentialityYour identity is often known internallyA qui tam case is filed under seal, protecting your identity
RiskCan tip off a dishonest employer to retaliate or destroy evidencePreserves evidence and your first-to-file position

Two legal rules make the channel matter. The first-to-file rule means only the first whistleblower to file a qui tam case on a given fraud can collect; the public-disclosure bar can block a case built on information already public. Reporting externally and under seal, through an attorney, protects both your reward position and your evidence.

Internal vs. External Whistleblowing

External Whistleblowing

You are acting as an external whistleblower when you take the misconduct you have witnessed to an entity outside of your organization. Some examples of an outside entity include:

  • A government agency that deals with fraud
  • A public fraud hotline
  • A media network
  • Your personal attorney

Out of these options, it is wise to speak to your whistleblower attorney first, whose duty is to represent your interests. Your attorney may want to recommend the next step you take, including which outside entity should receive the report.

Typically, only external whistleblowing ends in court actions. If you choose to report misconduct to a hotline, government agency, or prosecutor, you may lose all control of how the report moves forward.

You may be asked to testify about the accusations that you have made. Details that you have reported may be published without warning.

Internal Whistleblowing

You are acting as an internal whistleblower when you report wrongdoing to entities within your organization. Some examples of internal authorities may include:

  • Your immediate supervisor
  • Your organization’s human resource department
  • Your organization’s legal department

Most private and public organizations have protocols for dealing with accusations internally. Your report and the misconduct described in it may not ever be reported to outside authorities.

Should I be an External or Internal Whistleblower?

It can be challenging to decide if you should take your reports outside your organization. You should consider speaking to a lawyer before you make a decision. Whistleblowers are commonly subject to retaliation or reprisals for blowing the whistle and should be considered before coming forward with what you know. Asking yourself the following questions may help you consider all the factors:

"Most people assume the right thing to do is tell their boss. Sometimes it is. But at a company that's actually committing fraud, the internal report is the moment they learn who you are and start covering their tracks."


  • Is the misconduct a violation of the law?
  • Is the misconduct causing active harm?
  • Do you trust your organization to respond appropriately to accusations?

 

Is the misconduct against the law?

Some misconduct may be a violation of your organization’s ethical or behavioral standards, but it may not rise to the level of illegal behavior. In cases like these, you should make internal reports to resolve the misconduct.

You should consult a lawyer if you are unsure whether the behavior you’ve witnessed qualifies as a crime.

 

Is the misconduct causing active harm?

If you are aware of fraud against government programs, or practices that endanger others, you should consider making a report as quickly as possible. Making an external report may allow for the practices to be addressed more quickly.

 

Do you trust your organization to respond appropriately to accusations?

You should think carefully about how your organization will handle your complaint before deciding to blow the whistle internally. Not all organizations cultivate a culture where reports are taken seriously.

Filing an internal report can put you at risk of retaliation. It is illegal to retaliate against whistleblowers, but you may need a lawyer’s help to assert your rights.

 

Internal vs. External Whistleblowing FAQ

Q: What is the difference between internal and external whistleblowing?

A:    Internal whistleblowing is reporting the misconduct inside your organization, to a supervisor, HR, or legal. External whistleblowing is taking it outside, to a government agency, a fraud hotline, a court, or your own attorney. Only external reporting typically leads to court action and rewards.

Q: Which one gives me more legal protection?

A:    External reporting through the right channel, a qui tam filing, an SEC or IRS submission, an OSHA complaint, triggers the strongest federal protections and the chance at a reward. Internal reports are protected in many situations too, but the rules are narrower. A lawyer can tell you which channel protects you.

Q: Do I have to report internally first?

A:    Usually not. Most whistleblower laws, including the False Claims Act, do not require you to report inside the company before going to the government. In fact, reporting internally first can tip off your employer and give them time to destroy evidence or retaliate. Ask an attorney before you do either.

Q: Can I get a reward either way?

A:    Rewards come from external programs, not internal reports. A successful False Claims Act qui tam case pays 15 to 30 percent of what the government recovers; the SEC and IRS programs have their own award ranges. An internal complaint alone does not produce a bounty.

Q: Should I talk to a lawyer before I report?

A:    Yes. The path you pick affects your protections, your reward, and your job. A whistleblower attorney reviews whether the conduct is illegal, picks the channel that protects you, and handles the filing. These cases are handled on contingency, so the review costs you nothing.

How a Whistleblower Attorney Can Help

A whistleblower lawyer can help you at every stage of internal or external whistleblowing, and representation is required in qui tam cases where the relator brings suit on behalf of the government. Early on, your lawyer can assess the legal merits of your case, review the protections afforded whistleblowers by law, and help you protect your interests. Your lawyer will also help you prepare for the investigation by telling you what information can be collected legally, so you avoid running afoul of the law yourself.

If you are sitting on information and uncertain as to your next steps, take advantage of the offer for a confidential whistleblower attorney review of your potential case. Find out if you are eligible to file an FCA claim on behalf of the government, and if you decide to proceed, your lawyer will help you manage the case from start to finish.

Lawsuit Legal helps you choose the path that protects you and actually ends the misconduct. We tell you whether the conduct is illegal, which channel triggers the strongest protections, and how to report without handing your employer a reason to retaliate. We work on contingency. You Win or It's Free. Call (888) 713-6653 for a free, confidential review. We help the employees who saw something wrong and want to do it the right way.

 

 

 

 

 

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What best describes the nature of your case?
Do you have insider knowledge of fraud?
Are you still employed with the company?
Number of employees at the company?
Please describe briefly the nature of your case...
How to best contact with information about your potential False Claims Act case?
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