What is an I-9 Coordinator?
A unit’s I-9 coordinator is the person responsible for ensuring the federal employment eligibility form I-9 is filled out correctly and on-time. This is usually done as part of a new hire’s onboarding process, or as part of a re-hire process.
The I-9 Coordinator is responsible for ensuring we at UW are in compliance with federal law.
In addition to understanding, verifying, and completing the sections that are appropriate to the employee on time (within the first three business days of the employee’s first day of employment), I-9 coordinators are also responsible for:
- Ensuring no I-9 documents are missing
- Maintaining an ongoing audit of worker I-9 documents
- Monitoring the status of foreign national documents (like visas)
Where Can I Find Help?
- M-274 Handbook: this handbook was created by the governing body of the I-9, the USCIS, for you! Some highlights:
- ISC-Generated: designed to assist employees and I-9 Coordinators at UW.
- E-Verify: this website contains everything you need to know about E-Verify.
- Reports for I-9 Coordinators: this document (PDF) has summarized all of the reports that may be helpful to I-9 coordinators in Workday for auditing purposes. They should be run regularly, especially if you support foreign nationals.
Who Needs an I-9?
All workers, including Stipend and PDR workers, are required to complete Form I-9 due to the fact that those employees may move into a UW paid position, and would, therefore, need an I-9 on file. The I-9 must be on file within three business days of the employee’s first day of employment. The only exception is for workers with a job profile of “Unpaid Academic.” If those workers move into paid status, their Academic Partner will receive a “To Do” item in their Workday inbox to initiate the Onboarding process for the employee if necessary, which will include the prompt to complete a Form I-9.
New employees that do not have previous working relationships with UW must complete all sections of Form I-9 in Workday.
- Employee rehired within three years of completing a Form I-9 in Workday: only Section 3 is required, I-9 coordinator will be notified in Workday to complete this portion of the form. The Hire will not complete until this step is done by the I-9 Coordinator.
- Employee rehired who previously completed a paper I-9: Complete a new Form I-9 in Workday.
- Employee rehired more than three years after completing a Form I-9 in Workday: Complete a new Form I-9 in Workday.
Remote Hire Employees
USCIS Form I-9 is required for remote employees working within the United States. If you cannot physically be with the employee, the following are permissible:
- Another College or University can act as an agent of the UW to fill out the I-9. This will need to be done as a paper form. The completed paper form I-9 needs to be sent to the ISC for entry into Workday.
- Notary Public can be used to fill out the I-9. The completed paper form I-9 needs to be sent to the ISC for entry into Workday..
Reviewing or examining documents via webcam is not permissible.
I-9s and Stipends
The term “stipend” refers to a payment that is made to an individual to support a training or learning experience and not a payment for services rendered (see the UW Finance website for more detail). One time stipend payments may be paid through Procurement, Student Fiscal Services, or Workday depending on the scenario. Any stipends set up in Workday require an I-9 to be completed. Note: All stipends that are not one time payments must be entered in Workday. Stipends for employees with a position in Workday for the current tax year must be paid through Workday only.
- One-time Non-Student Stipends: Pay through Procurement
- One-time Stipend for Students without Benefits: Pay through Student Fiscal Services
- Stipend for Students with Benefits or Non-Resident Differential Waiver: Pay through Workday
The Form I-9
The I-9 has three major sections:
- Section 1 of the I-9 is filled out by the employee. The I-9 coordinator will review it carefully to ensure that it has been filled out in accordance with standards.
- Section 2 is filled out by the I-9 coordinator as the appropriate documents are presented by the employee.
- Section 3 is filled out by the I-9 coordinator in the event that the employee is either:
- Reverifying their employment authorization
- Reverifying or updating their employment authorization as a result of a re-hire
- Recording changes of name and other identity information
What to Look for in Section 1
Section 1 of the I-9 can contain several mistakes, but the most common one is the question in this section where the employee attests to their citizenship status. Be sure to use and distribute the resource below to ensure all employees are filling Section 1 out properly.
“Aliens authorized to work”, aka Foreign Nationals
An alien authorized to work is an employee that is not:
- A U.S. Citizen/Naturalized U.S. Citizen
- Born in American Samoa or on Swains Island (noncitizen national)
- A lawful permanent resident (has a green card aka an alien registration number)
Common visa types for foreign nationals are included in the matrix below. This population is required to enter an expiration date for their I-9 work authorization. This can be confusing to find! Use this matrix to help:
|Visa Type||Which Associated Form the Date is On?||Field Name on the Form|
|F-1||I-20||Program End Date*
*On an old form I-20, revised in 1988, the latter date on Question 5, “complete studies no later than…”)
|J-1||DS2019||3. Form Covers Period: > To (mm-dd-yyyy):|
|TN||I-797A or I-797B||“Valid to” date in Notice Type box|
|H1-B||I-797A, I-797B, or
Employment Authorization Card
|“Valid to”, or
|F-1 OPT, DACA, H-4, J-2, L-2||Employment Authorization Card||Card Expires|
What to Look for in Section 2
Section 2 is your chance to check the employee’s work and add record of the appropriate documents. Be sure they are filling out Section 1 properly and you are entering information in Section 2 properly using the journey map below.
What to Enter in Section 3
Section 3 of the I-9 should be used only for below scenarios:
- Employee has a legal name change. Navigate to the Employee’s existing I-9 form in Workday, and select the “Section 3 Reverification” button. Note any name changes in Section 3 and be sure to validate the legal name change by reviewing proof/documentation of legal name change.
- Employee is rehired within three years of the date that Form I-9 was originally completed. If you rehire your employee within 3 years of the date that a previous Form I-9 was completed in Workday, you may either complete a new Form I-9 for your employee or complete Section 3 of the previously completed Form I-9. Be sure to review the original Form I-9 to determine if your employee still has valid work authorization. If yes, then enter the date of rehire in Section 3, else, request that the employee present an unexpired document. Enter the document information and the date of rehire in Section 3.
- Employee’s employment authorization or documentation of employment authorization has expired (“reverification”.) I-9 coordinators are encouraged to regularly audit for expiring documentations using the ‘U.S. Employees with Expiring Form I-9 Documents’ report in Workday. For individuals that are returned on this report, request the employee to present a new unexpired work authorization document. Navigate to the Employee’s existing I-9 form in Workday, and select the “Section 3 Reverification” button. Record the document title, document number, and new expiration date (if any) in Section 3.
How to Audit I-9 Completion and Expiring Documents
Reports for Completing an Initial Audit
Worker I-9 Audit for Previous/Current System
The ISC has created the Worker I-9 Audit for Current/Previous System report in Workday to provide you an easy way to review I-9s recorded in Workday and in our legacy systems. Though Workday comes with a number of delivered reports, they will sometimes produce misleading data because they do not account for I-9s collected before Workday go-live.
Reports for Regular Monitoring
Onboarding Status Summary
This report provides a summary for workers in various stages in the onboarding process. The report will list the remaining and completed steps (as well as steps not started), and includes an overall completion percentage for all onboarding tasks, including the I-9 completion. We recommend running this report every Tuesday and Thursday to keep an eye on your unit’s recent hires.
Worker I-9 Audit for Previous/Current System
Once an initial audit is complete and all paper forms recorded in Workday, it will remain the responsibility of the I-9 Coordinator to ensure compliance by monitoring whether new employees have completed the I-9 form. We suggest running this report every Tuesday and Thursday to ensure you have a view into the I-9 status of all employees.
- Run the Worker I-9 Audit for Current/Previous System Report with the following parameters:
- Effective Date: Use today’s date
- Hired On or After: Leave blank
- Hired On or Before: Today’s date
- Employee Type: Leave blank
- Worker: Leave blank
- Leave all check boxes checked
- Review your report results.*
- If your report returns no data, then all employees in your unit have completed forms and no further action is needed.
- If workers are returned:
- Look in the Form I-9 Awaiting column to see remaining actions required
- If employee action is needed, tell employee to initiate the I-9 process in Workday in one of two ways:
- Locate the I-9 action item in their inbox
- Manually launch the I-9 process by typing “Complete Form I-9” into the Workday search field
- If I-9 Coordinator Action is needed: Complete Section 2 of the Workday Form I-9 process (refer to the User Guide)
- Choose the appropriate “late reason”
*You can see more detail about each process by selecting the process link and then reviewing the Process tab on the next screen. The process details will help you determine what is holding up the process and who should take action. For example, if the process may appear incomplete if employees have not submitted the To Do “provide I-9 Coordinator with acceptable identification.”