I-9 Employment Eligibility Verification

I-9 Resources

The hiring manager or appropriate administrator in the hiring department is responsible for completing the Form I-9, Employment Eligibility Verification (I-9) with each new hire as required by federal law. This form must be signed by the employee on or before the first work day, and the employer section must be completed no later than the third work day, so compliance with this requirement can be challenging. Additional instructions are available for remote hires.

The Checklist for Completing an I-9 provides instructions for this process. You can download the printable version of the checklist and refer to it as needed.

The I-9 Training Presentation is a great tool for on-demand training of hiring managers and administrative support staff who are new to the I-9 process. This PowerPoint presentation gives a general orientation on the purpose of the form and steps for completing it.

The federal government provides an excellent resource for both general and in-depth questions about I-9 compliance. The I-9 Handbook for Employers is an easy-to-navigate PDF document with detailed explanations and illustrations.

Checklist for Completing an I-9

Section 1: Employee Information and Verification

To be completed on the first day of work. Earlier is acceptable, but the form cannot be completed before the employee has been hired.

1. Give the employee a Form I-9 including instructions. Ask him/her to complete Section 1 and bring an acceptable combination of documents.
   Note: Let the employee choose the documents! Never request specific documents.
2. Check that the employee has completed all fields:
   • Name: The employee must use his/her legal name in correct order.
   • Address, Date of Birth, Social Security Number
   • Citizenship Attestation
     • A Lawful Permanent Resident must provide an 8- or 9-digit Alien Number.
     • An Alien Authorized to Work must provide the work authorization expiration date and an Alien number or an 11-digit Admission number from the Form I-94.
   • Sign and Date: The form is not valid without a signature.
3. Preparer and/or Translator Certification: If someone other than the employee completed Section 1.

Section 2: Employer Review and Verification

To be completed and returned to HR Records no later than the employee’s third work day by an authorized representative of the hiring department. (Contact your supervisor or the HR Contact in your department to find out if you are authorized to sign this section.)

1. Accept the combination of documents presented. Accept only originals and do not ask for or accept more than is required.
   • Valid documentation is one of the following: One document from List A, or one from List B and one from List C.
   • Be sure the employee has signed the documents.
   • Note that Foreign Passport with an I-94 Arrival/Departure Record requires an additional Work Authorization document, such as I-20 or DS-2019.
   • Make a readable copy of each document.
2. Record each document title, issuing authority, document number, and expiration date (if applicable). Use the correct lines according to the key at the far left of the page. Be sure to use the correct column for List A, B, or C.
3. Enter the employment start date (month/day/year). Use the current date, if you are completing the form before the employee’s actual first day of work. Do not leave this space blank!
4. Sign and date
   • Only the person who viewed the original documents can complete this section.
   • Address should include the name of the university department or unit.

Section 3: Updating and Reverification

Only use this section when the employee’s work authorization has changed or has a new expiration date.

Handling the Completed I-9

1. Make and keep a copy of the completed I-9 and all supporting documents for the employee file.
2. Immediately forward the original I-9 with all supporting documents to your campus HR office.

Troubleshooting

1. Employee name does not match the documents provided.
   • The employee must use his/her legal name. If he/she is in the process of changing names, use the current name on the I-9 form and the employee record. Once the name has been changed, he/she can present proof at Payroll Services to update his/her employee record.
   • If the employee presents a Social Security Card, the name on the Form I-9 must be the same as the name on the card.
2. The employee does not have a Social Security Number.
   • A citizen of the U.S. must provide proof from the Social Security Administration that an application has been made. Complete Section 2 of the I-9 using the information on the letter, if the Social Security Card is a supporting document.
   • For international employees, coordinate with International Student and Scholar Services and Payroll Services as needed. Refer to the Payroll Services webpage “Social Security Numbers for Non-United States Citizens,” for instructions.
3. The employee has a “delay” letter saying he/she has applied for the document(s).
   • Most official delay letters are acceptable. Use the information on the letter to complete the I-9 and send the form to HR as usual with a copy of the letter attached.
4. The I-9 Form is late.
   • Do not backdate the form. Explain why the document is late on a separate sheet of paper. Sign and date it and attach it to the original I-9. Remind all involved that federal law requires this form to be complete no later than the third workday.
5. The employee does not provide acceptable documents by the third workday.
   • Employment should not continue. Contact Human Resources for assistance and referral. It may be necessary to work with HR Recruitment and Employee Relations to dismiss the employee.
6. The employee is dismissed, quits, or stops reporting to work before completing the I-9 process.
   • Explain why the document is incomplete on a separate sheet of paper. Sign and date it and attach it to the original I-9.
   • If the employee had not completed Section 1, write the employee’s name and IRIS ID at the top of a form I-9 and attach the explanation. Remind everyone involved that the I-9 process is a federal requirement and each new hire should complete Section 1 by the start of the first workday without exception.