One of the examples in the article is upgrading a dependency. This could easily fall into the category you mention if the upgrade itself is not properly tested. A considered approach would be:
"I want to make a small improvement, oh I see this dependency is out of date and has some minor vulnerabilities or perf issues, or is missing a feature that could come in handy for XYZ. Hmm, there are no tests confirming our assumptions about the current library version, nor are then any tests are our code / systems that use it. I guess my improvement should be to add those tests, then next time someone has the same idea it'll be an easier upgrade"
I am unsure but I also interpret from your first sentence that you may have seen people use this rule as a defence for gold plating (the opposite of KISS or YAGNI). Similarly this should fall under the heading of changes made without proper discussion, thought or consideration.
Otherwise I think we're really stuck, if team members cannot be trusted to properly interpret the boy scout rule without messing up a codebase then how on earth can they be trusted to build the foundation of their company / team / system?