Published on: June 16, 2025
An ATIXA Tip of the Week by Joseph Vincent, M.L.S.
Hiring an external investigator to conduct a Title IX investigation can be expensive, and it’s not always necessary. Many institutions have internal investigators who are well-trained, experienced, and fully equipped to address most complaints. Still, there are moments when turning to an external professional is not just helpful, it’s the strategic choice that protects the integrity of your process and your institution’s reputation.
Do you need to move a particular investigation to an independent third-party investigator? Like most complex challenges, the answer is usually “it depends.” The factors influencing your decision will vary from case to case and even more significantly between institutions. Still, there are reliable criteria that should be part of the conversation. You should consider using an external investigator when:
- A high-level administrator is implicated in misconduct
- Institutional misconduct is implicated in the complaint
- This investigation is being used to cure a previous, failed investigation
- The scope of the investigation requires a deeper bench of investigators than is available internally
- The sophistication of the investigation requires professional expertise
- There is a concurrent criminal investigation or charges related to the incident
- The complaint has a high level of public or media attention
- The allegations involve a polarizing or politically sensitive issue
- There is an actual or potential conflict of interest (e.g., staff have pre-existing relationships with the parties)
- The Title IX Office faces capacity challenges that could delay a prompt investigation
- There have been prior accusations of bias against the office or institution
- The complaint involves emerging, complex, or unsettled legal issues
- There are settlement agreements or OCR resolution terms encouraging external review
In these situations, an external investigator provides critical distance from campus politics, offering parties greater confidence that the process is fair and impartial. Their expertise can help institutions navigate novel legal questions, manage media narratives, and avoid costly missteps that could expose the institution to litigation or reputational damage. An external investigator also often brings procedural fluency. Remember, this is their day job, and they do it all the time. They’ve likely seen everything, confronted every obstacle, and faced every conceivable challenge. A seasoned professional will help you to ensure an industry-standard investigation that is in full compliance with federal regulations, institutional policies, and best practices, with minimal disruption to campus operations.
Estimating the Financial Cost
External investigations in the field typically cost between $150 and $850 per hour, with the most common rates falling between $300 and $450 per hour when flat fees are not applied. Based on TNG’s internal data:
- Most investigations are completed between 12 and 30 hours, with a median time of 17 hours
- Most investigations that take over 20 hours are completed between 31 and 78 hours, with a median length of 48 hours
- Our longest investigation to date took 250 hours to complete
Protecting Rights and Preserving Trust
Hiring externally doesn’t signal a weakness in your internal process—it signals a maturity in your approach to institutional risk and fairness. It shows that your institution knows when to bring in additional resources to safeguard the credibility of the process, particularly when the stakes are high. Leaders who invest in neutrality and thoroughness send a powerful message: the institution is committed to upholding the rights of all parties and maintaining trust in its Title IX program.
External investigators are likely not needed for every complaint, but when used strategically, they can be a vital tool for protecting the rights of the parties, preserving community trust, and strengthening the overall integrity of your response. Thinking critically about when and how to make that call is part of a robust, resilient Title IX strategy.
TNG’s investigators deliver thorough, defensible civil rights investigations that help institutions manage legal risk. External support of this kind can be especially valuable in complex or sensitive matters. Contact us at inquiry@tngconsulting.com to learn more.