It is important for employers to complete their I-9 forms properly for each employee they hire under the Immigration Reform and Control Act (IRCA) of 1986. Employers can face criminal punishment if the I-9 forms defy verification and employment eligibility requirements.
To prevent any mistakes in your I-9 forms, it is helpful to regularly conduct an I-9 audit internally. Below is our I-9 audit checklist to help you conduct the audit seamlessly and ensure that you don’t forget anything during the process.
What You’ll Need
In order to perform your I-19 audit correctly and thoroughly, you’ll need the following:
- List of current employees
- List of employees that were terminated in the past three years
- Copies of all I-9 forms (either original or electronic)
- Current I-9 form requirements
- Up-to-date version of the USCIS’s Form I-9 M-247 Handbook for Employers
I-9 Audit Checklist Steps
1. Employee Information
First, ensure that you have the following information available for each employee and check to see if it is correct:
- Employee first and last names
- N/A for “Other Names Used” if it is not applicable
- Maiden name or other names if it applies
- Full address (excluding PO boxes)
- Date of birth in mm/dd/yyyy format.
- Social Security number (this is mandatory for E-Verify participants)
2. Citizenship or Immigration Status
Check to see that the following information regarding citizenship or immigration status is correct and competed:
- Status (Make sure only one is selected)
- Lawful Permanent Resident: make sure the alien registration number is included
- An Alien Authorized to Work: ensure the work until date, alien number or admission number is correct
- Expiration date of employment authorization
3. Employee’s Attestation
Next, you’ll want to review your employee’s attestation. Ensure these next items are complete and accurate:
- Employee’s signature
- Date of employee’s execution of form
- Date of employees first day
* I-9 must be signed within 3 days of start3
4. Identity and Employment Eligibility Provided Documents (List A)
Ensure you have the appropriate information regarding identity and employment eligibility as well:
- Correct document listed
- List A document title
- List A document issuing authority
- List A document number
- List A document expiration date
- Receipt showing accepted application for document
5. Identity (List B)
For List B, ensure the following are complete and accurate:
- List B document title
- List B document issuing authority
- List B document number
- List B document expiration date if applicable
- Receipt showing accepted application for document
6. Employment Authorization (List C)
For List C, ensure the following are complete and accurate:
- List C document title
- List C document issuing authority
- List C document number
- List C document expiration date if applicable
- Receipt showing accepted application for document
7. Employer’s Certification Information
Next, review your employer’s certification information by checking the following for accuracy and completion:
- Employee’s first day of employment in mm/dd/yyyy format
- Signature of Employer/Authorized Representative in the correct box
- Date of certification in mm/dd/yyyy format
- Certification signed within three days of hire
- Title of Authorized Representative
- Last Name and First Name of Authorized Representative
- Employer’s Business or Organization Name
- Address of business (No P.O. boxes are allowed)
8. Reverification Requirements
The only instance reverification is applicable is if employment authorization evidence presented in Section 2 becomes expired. You do not need to reverify US citizens, noncitizen nationals, or Lawful Permanent Residents.
However, if reverification is necessary, check for completion and accuracy of the following items:
- Date of rehire in mm/dd/yyyy format if applicable
- New name listed if applicable
- Document title
- Document number
- Employment authorization document
- Expiration Date in mm/dd/yyyy format
- Signature of Authorized Representative present
- Date of company certification in mm/dd/yyyy format
- Printed name of Authorized Representative
What To Do About Missing I-9’s
Protocol for missing I-9’s differs between current and former employees. For current employees, have your employee present the appropriate documentation and complete an I-9, filling it out with the current dates. Then, attach a note explaining why there is a discrepancy between the hiring date and the I-9 form completion date.
For former employees, date and attach a note to an I-9 form for former employees, filling out any missing or incorrect information. Then, put the form with your other I-9 forms.
What To Do with I-9s with Errors
If the errors are easily correctable, you can correct these errors directly on the form. Cross out the incorrect information in a contrasting color of ink and put the correct information next to it. Initial and date next to each correction. If the errors cannot be corrected easily, you must complete a new I-9 form. Attach this new form to the new one with a note that explains why you are filling out a new form. Make sure to not throw away the old form.
How to Store I-9’s
Keep your I-9 forms separate from employee personnel files. It is strongly recommended to store your I-9 forms both electronically and in the form of a hard copy. Ensure that these files are only able to be accessed by a few HR representatives.
EPAY Can Help Improve Your HR Department’s Efficiency
From our human management software to our helpful human resources-related tips, EPAY is here to help your human resources department run more smoothly. For more information on proper I-9 practices or if you have other HR-related questions, please contact our team at EPAY today.