  In theories with radiative symmetry breaking, the calculation of the false
vacuum decay rate requires the inclusion of higher-order terms in the
derivative expansion of the effective action. I show here that, in the case of
covariant gauges, the presence of infrared singularities forbids the consistent
calculation by keeping the lowest-order terms. The situation is remedied,
however, in the case of $R_{\xi}$ gauges. Using the Nielsen identities I show
that the final result is gauge independent for generic values of the gauge
parameter $v$ that are not anomalously small.
