I-9 Self-Audit: 5 Steps to Get Started

This is the second of a four-part series for HR professionals, called “I-9 Audit and Remediation Best Practices.” 

As we discussed in our first post, "What is an Internal I-9 Audit? And 5 Reasons to Audit Now," an internal I-9 audit or an I-9 self-audit is not required by law. However, it is often used as a best practice to help manage I-9 compliance. The goal is to identify I-9s that are missing, incomplete or have issues. Before you begin your audit, follow these steps in preparation.

5 Steps to Prepare for an I-9 Self-Audit

  1. Get a list of all current and former employees hired since November 6, 1986.

    The Immigration Reform and Control Act (IRCA) forbids employers from knowingly hiring individuals who do not have work authorization in the United States. The Immigration and Nationality Act (INA) contains the employment eligibility verification provisions of IRCA.  To comply, an employer must verify the identity and employment authorization documents of employees hired after November 6, 1986.  Additionally, employers must complete a Form I-9 for each employee hired after November 6, 1986.
  2. Gather all Form I-9 documents (electronic or paper) for all current and former employees.

    During the process you will audit all Forms I-9 to identify those that are missing or have issues. You will need all documents, whether electronic or paper, ready for your review.
  3. Download the most current version of the M-274 Handbook.

    U.S. Citizenship and Immigration Services (USCIS) publishes the M-274, the Handbook for Employers. The M-274 covers everything from why employers must complete Form I-9, to guidance for each section, and more.
  4. Review guidance for employers.

    The Department of Homeland Security and the Department of Justice have provided help for employers to perform an I-9 self-audit. The document titled, "Guidance for Employers Conducting Internal Employment Eligibility Verification Form I-9 Audits," covers items such as the appropriate scope of an audit, as well as guidance for avoiding discriminatory actions and much more.
  5. Purge I-9s that have met retention requirements and focus efforts on current I-9s.

    During your preparation, weed out forms you no longer need. You must keep Form I-9 on file for all current employees.  Keep a terminated employee's Form I-9 on file for three years after the date of hire OR one year after the termination -- whichever is later. Avoid wasting time auditing and correcting I-9s you no longer need.

Stay tuned for the next post in the “Internal I-9 Audit and Remediation Best Practices” series for tips on what to look for in each section of Form I-9 during an I-9 self-audit.

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