Memo To: CLA unit administrators
From: Jennifer Cieslak, Chief of Staff Scott Appelwick, Assistant Director, Financial Services
RE: I-9 Requirements and Compliance with Federal Law - Urgent
We write to remind you of the urgency of complying with federal law by ensuring that all new employees complete both parts of the I-9 form electronically within three days of the start date of their appointment.
In this memo, we also restate roles and responsibilities for I-9 completion and compliance, summarize the implications of the changes in how the I-9 work is done, including the use of the new e-Verify system, and note the consequences of an employee not completing the I-9 in a timely manner.
As earlier communicated, federal law mandates that any new employee must complete their I-9 within the first three days of their appointment. This law is not new.
What is new, however, is that the University must now process all I-9's electronically utilizing e Verify. This takes away any "wiggle room" that may have existed in the past in meeting this requirement.
Administrators are responsible to ensure that every new hire has completed their I-9 Form within three days of their appointment date.
After three days, administrators must notify their financial service team to suspend or terminate all new hires who have not completed their I-9.
Your Financial Service Team is available to assist in this endeavor.
Department administrators are responsible for ensuring that all new employees (i.e. faculty, instructional staff, graduate assistants, student workers) complete Section 1 of the I-9 (online) prior to the start of their appointment and making sure they complete Section 2 within the first three days of their appointment start date.
Completing Section 1 prior to their first day provides new staff with the list of acceptable documentation from which they are to choose one to bring with them on days one, two, or three.
Further, within the first three days of their appointment, the new employee must visit one of the financial service teams to complete Section 2 of the process. Your financial service teams are poised for the rush of I-9 work that will need to be completed during the first three days of fall semester (i.e., August 31, September 1 and September 2).
We will have "all hands on deck" in order to complete this work as efficiently as possible.
Numerous appointments have already been scheduled for the financial service teams' Executive Account Specialists (EAS) to attend departmental orientation sessions as a way to further be efficient in this endeavor. Let us know if you have other ideas that will be helpful to you.
Federal law mandates that we not allow continued employment for anyone who has not completed their I-9 form within the first three days of their appointment.
For those who do not complete their I-9 form within the first three days of their appointment, University administration has instructed us to suspend or terminate them (depending on the type of appointment) on day four; further, we have been instructed to not un-suspend or reappoint them until the I-9 work is completed. Please note that the suspension/termination could have significant impact to an employee's pay, benefits, and immigration status. Also, any I-9's that are completed after the third day must have a detailed explanation as to why the form is being processed late. In the event of an audit, this detailed explanation will be the University's only defense.
It is the department's responsibility to initiate the suspensions or terminations. Your financial service team is available, upon request, to help in this endeavor, such as assisting in keeping track of who has not yet completed their I-9. Once the administrator has found that an I-9 was not completed by the third day of the appointment, the administrator must contact the senior accountant on the financial service team to inform the senior accountant to process the suspension or termination.
CLA wants to do all it can to avoid placing people in a suspend or termination status; therefore we ask that departments and fiscal teams work closely together to plan, anticipate, and communicate, so that no one is removed from payroll. Please communicate this message to your hiring managers, Directors of Graduate Studies, DGS assistants, and anyone else who needs this information. We fully realize that for some departments this will require a change in workflow and in how new staff are brought on board. It is a responsibility that we all share as we work to keep the University in compliance with this federal law.
Please see attached FAQ for further information regarding I-9 processes.
If you have any questions, please contact your unit service team lead or your HR representative.
Thank you for your cooperation.