I-9 Audit Procedure
[Note: This procedure is based on a paper based I-9 system; however, a parallel process could be followed for those using fiche or electronic based I-9 document retrieval and systems]
Before commencing the audit, print updated employee roster(s) of active, inactive and terminated employees for use in the audit. Then pull the binders which house active, inactive and terminated employee I-9 documents, the re-verification tickler file, and purged document roster.
For active and inactive* employee I-9s,
Step 1: Match employee I-9’s to rosters. (Remember that all employees who were hired on or after 11/6/86 must have a completed I-9. Thus, for all employees hired or re-hired prior to this date, there will be no I-9 form. All employees hired or rehired after 11/6/86 must have a completed I-9.
If no I-9 is located for an employee, note this on the roster as a corrective action item.
For corrective action to cure the deficiency, an I-9 must be completed. In completing the I-9, do so using the date of the audit or the date supporting documents are reviewed, do not back date the I-9.
Step 2: Inspect Sections 1 and 2 to ensure that they are completed properly. Note: Section 3 should only be completed for changes, employment re-verifications and re-hires.
If deficiencies are noted or if information is incomplete in Section 1, have the employee insert correct information as appropriate and date and initial the I-9 using the date corrected. If Section 2 has deficiencies or missing information, correct or add information as appropriate and then date and initial the form using the date corrected.
Step 3: Ensure that information is current and that employment authorizations are still valid. Review roster names against I-9’s for any names changes and that employment authorizations provided, i.e., visa authorization dates, remain valid (using the re-verification tickler file).
If deficiencies are noted or re-verification is required, enter updated data in Section 3 of the form using the date changes or re-verifications have been conducted. Remember that documents supporting the change or re-verification must always be viewed when Section 3 is completed.
For terminated employee I-9’s
Begin purging of I-9’s by using USCIS guidance, remove only I-9’s which are beyond three years from date of hire or one year from date of termination, whichever is later.
I-9’s purged should be noted on the I-9 purged roster with the date of purging and purged I-9’s should be moved to the shred destruction area. Add names and dates purged to the purged roster prior to shredding documents and re-file the updated roster.
*Inactive employees are those on approved leave of absences and laid off employees with recall/service bridging rights.
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