The Higher Ed Workplace Blog

4 Essential I-9 Resources for Higher Ed


The devil is in the detail, and nowhere is that more apparent than with Form I-9 compliance. Civil enforcement of I-9 requirements often focuses on form over substance, which means paperwork errors can result in fines of hundreds of thousands of dollars even without evidence of the employment of unlawful immigrants.

Throw in the mergers that have taken place in higher education over the past few years, and the volume of paperwork (and potential for error) can increase substantially. Carolyn Knight-Cole, associate vice president of human resources operations at Rutgers University, recently found herself with thousands of I-9s to review and, in some cases, reverify after her institution merged with another.

How can higher ed employers manage the  I-9 process to ensure that their efforts will withstand scrutiny by Immigration and Customs Enforcement (ICE)? Here are four resources that can help:

“Form I-9 Requirements: Why Compliance Matters”
This webinar, recorded in April 2014, offers clear instructions about how to complete the form, common mistakes to avoid, and tips for surviving an ICE audit. The recording is available with closed captioning. A summary document is available as a supplement to the recording.

A Deeper Dive Into Compliance Issues
In this follow-up piece, webinar presenter Patrick Shen of Fragomen, Del Rey, Bernsen & Loewy, LLP, answers questions from the webinar audience, including questions about remote hires, adjunct faculty, re-verification, correcting form errors, preserving an “audit trail,” and complying with anti-discrimination provisions under federal immigration law.

CUPA-HR’s I-9 Reciprocal Processing Consortium
Completing I-9s for hires who are located outside the hiring institution’s home state can be a challenge. At the request of members, CUPA-HR created an I-9 Reciprocal Processing Consortium, a network of institutions across the U.S. willing to assist other institutions with the verification process.

 I-9s/E-Verify Toolkit
Located in the CUPA-HR Knowledge Center, this toolkit features how-tos for managing files and completing internal audits, plus sample forms and other helpful resources.

“As a large employer with employees around the nation and around the globe, we sometimes struggle with the compliance piece for the I-9 Employment Eligibility Verification process for remote hires.  The resources that CUPA-HR makes available – particularly the I-9 Reciprocal Processing Consortium – make the difference between complying with this federal mandate for employees who are out-of-state, and subjecting my university to financial penalties for non-compliance.” – Carolyn Knight-Cole