Form I-9 Policy

PURPOSE

As part of the Immigration Reform and Control Act of 1986, the Form I-9 is used to verify the identity and confirm the employment authorization of individuals hired for employment in the United States. All U.S. employers must ensure proper completion of the Form I-9 for each individual they hire for employment in the United States. This includes citizens and non-citizens.

Both employees and employers (or authorized representatives of the employer) must complete the Form I-9. On the Form I-9, an employee must attest to his or her employment authorization. The employee must also present his or her employer with acceptable documents evidencing identity and employment authorization. The employer must examine the employment eligibility and identity document(s) an employee presents to determine whether the document(s) reasonably appear to be genuine and to relate to the employee and record the document information on the Form I-9. The list of acceptable documents can be found on the last page of the form. Employers must retain the Form I-9 for a designated period and make it available for inspection by authorized government officers.

To ensure the College stays compliant with the law, hiring authorities must verify an employee’s identity and work authorization by completing the Form I-9 as noted above. 

The Form I-9 is a three-page form comprising three sections. Each section contains different requirements, and failure to comply would result in delayed hiring, transmission of incorrect data to USCIS for E-Verify purposes and civil penalties.

Section 1

Upon hire, the employee will complete Section 1 of the Form I-9. Human Resources will ensure that Section 1 is complete no later than the employee's first day of employment.

If Section 1 is not completed by the first day, the issue will be escalated to the hiring manager or VP of the respective area.

Updates and Re-verifications:

Section 3 may be used to re-verify or update work authorization for existing employees and for rehires. The same Form I-9 may be used for reverification if  less than three (3) years of employment. Otherwise, a new Form I-9 should be used for re-verification and for updating.

Rehires

When rehiring an employee, Section 3 of the Form I-9 may be used if the employee was rehired within three years from the date of the previous Form I-9. Otherwise, a new Form I-9 must be used, and Section 1 and Section 2 must be completed.

REMOTE HIRES AND VERIFICATION

If there are employees physically present at a work location, no exceptions are being implemented at this time for in-person verification of identity and employment eligibility documentation for Form I-9, Employment Eligibility Verification.

• Federal law permits the services of an unauthorized representative to complete the employee’s I-9 form on behalf of the College..
• The I-9 form can be sent via fax or mail.
• The I-9 Form cannot be notarized.
• HR cannot accept copies of identification documentation.

For remote hires, the college will not predefine remote authorized representatives; however the college authorizes the representative as follows:

• The College and University Personnel Association (CUPA-HR) has developed a Form I-9 Reciprocal Processing Consortium which is a listing of higher education institutions who are willing to provide reciprocal processing of Form I-9.

Human Resources will assist the employee with finding an institution to assist with the Form I9 verification.

Additional information:

• The employee must pay any fee(s) charged by the Section 2 completion if the authorizing authority is not a member of the CUPA-HR Reciprocal Processing Consortium.
• Section 2 of Form I-9 must not be completed by the new employee or friends or family of the new employee.
• If a remote authorized representative cannot be found or is unwilling to complete the Form I-9, contact Human Resources.