HRM-022: Employment Eligibility Verification (Completing Form I-9)

Date: 09/20/2010 Status: Final
Last Revised: 03/21/2013
Policy Type: University
Contact Office: Compliance (UVA HR)
Oversight Executive: Vice President and Chief Human Resources Officer
Applies To: Academic Division and College at Wise
Reason for Policy:

The University is committed to complying with federal laws concerning employment eligibility of employees hired to work in the United States. In accordance with the Immigration Reform and Control Act (IRCA) of 1986, the University is required to verify the identity and employment authorization of all employees by completing the federal Employment Eligibility Verification Form I-9 (I-9). Under IRCA, the University must not knowingly hire or continue to employ any person not authorized to work in the United States, and must not discriminate because of national origin against U.S. citizens, lawful permanent residents, or authorized aliens.

Definition of Terms in Statement:
  • I–9 Specialist:

    An employee designated by a hiring unit within a school or department who is authorized to complete the online I-9 form on behalf of the hiring department. This individual is authorized upon satisfactory completion of training provided by University Human Resources.

Policy Statement:

The hiring official or the I-9 Specialist must verify identity and employment eligibility of all newly hired and rehired employees, and those employees whose employment authorization has expired. Employment eligibility must be documented using the I-9 form for each employee hired or rehired after November 7, 1986. I-9 Specialists are required to inspect documents produced by employees for genuineness in order to substantiate employee identity and employment eligibility.

The Immigration Reform and Control Act (IRCA) requires that the I-9 employment verification process be completed in person by the hiring official, or the I-9 Specialists, or by an agent designated to act on behalf of the University and perform the required document inspections.

The failure of a department to complete in a timely fashion the Form I-9 or of the employee to provide the required documentation within three business days of the commencement of employment will result in removal of the employee from the payroll system until the documentation is completed and submitted.

  1. Responsibilities:

The employee is responsible for:

  • Accurately and truthfully completing Section 1 of Form I-9 no later than the close of business on the first day of employment; and
  • Presenting prescribed, genuine, original documents establishing identity and employment authorization to the department hiring official or to University Human Resource (UHR) no later than three business days after commencing employment.

The hiring official is responsible for:

  • Directing newly hired student wage, faculty and staff employees to a designated I-9 Specialist for completion of Form I-9 no later than the close of business of the employee’s first day at work; and
  • Completing Section 2 of Form I-9 no later than three business days after commencing employment.

The I-9 Specialist in the hiring department is responsible for:

  • Overseeing the I-9 process for all student wage, faculty, and staff hires;
  • Ensuring that the employee has accurately completed Section 1 of Form I-9 no later than the close of business of the employee’s first day of employment;
  • Accurately completing Section 2 of Form I-9 no later than the close of business on the third day of the employee’s employment;
  • Re-verifying employment authorization for employees whose authorization has expired; and
  • Coordinating remote I-9 completion by authorized representatives of the University and ensuring that I-9s completed by such representatives are submitted to CIS.

University Human Resources is responsible for:

  • Managing the University’s employment verification process and monitoring compliance with federal and state laws and policies;
  • Tracking all employees for whom no I-9 has been submitted and notifying departments;
  • Taking appropriate actions through the Integrated System for employees having no I-9 on file;
  • Tracking the expiration of employment authorization documents and notifying employees of the approaching expiration;
  • Maintaining completed I-9 forms per federal regulations; and
  • Providing training and consultation on the I-9 process to those individuals who are designated by departments as involved in the hiring process, specifically, for training designated I-9 Specialists.

Conducting the Employment Eligibility Verification (Completing the I-9 Form)
Offsite Employment Verification Instructions

Major Category: Human Resource Management
Approved by, Date: Policy Review Committee, 05/13/2009
Revision History: Updated 3/21/13, 9/20/2010.
Supersedes (previous policy):
New Hire Employment Eligibility Verification (I-9)