Navigating the End of Remote I-9 Verification: 4 Steps to Prepare for In-Person Review

Throughout the COVID-19 pandemic, employers were given the flexibility to verify I-9 forms remotely. However, as the Department of Homeland Security (DHS) signals the end of this policy, it is crucial for employers to prepare for the transition back to in-person verification. In this blog, we will outline four important steps you need to take to ensure a smooth process during the in-person review of I-9 documents.

Step 1-
Document the Physical Inspection If the same individual who conducted the remote inspection is available to perform the physical review, they should note the date of the physical examination and add their initials in the Additional Information field of the Form I-9. For example, they can write: "COVID-19; Documents physically examined on [DATE] by [INITIALS]."

Step 2-
Address Changes in Employer Representatives In cases where the original employer representative who conducted the remote inspection is no longer with the company or unavailable for the in-person review, a new employer representative should complete a new Page 2, Section 2 of Form I-9. This new form should be attached to the employee's existing I-9 to ensure proper documentation.

Step 3-
Expired Documents Remain Acceptable If any of the documents presented during the original remote I-9 process have expired since then, they can still be considered valid for the in-person review. As long as the document was valid at the time the original Form I-9 was executed, it can be accepted during the in-person inspection.

Step 4-
Dealing with Lost or Unavailable Documents In situations where a document that was previously reviewed remotely has been lost or is unavailable for in-person inspection, the employee should complete a new Section 1 of Form I-9. The employee should then present any qualifying document from List A, or a combination of documents from Lists B and C. The new Form I-9 should be attached to the original, and the employer's representative must indicate the same hire date on the new form. In the "Additional Information" field, it should be noted that the new I-9 was necessary due to the unavailability of the employee's original documents.

As the end of the remote I-9 verification policy approaches, employers must prepare for the in-person review of I-9 documents. By following these four essential steps, you can ensure compliance and a smooth transition. Stay updated on any further developments and guidance by subscribing to FutureSense’s blogs. Our team is here to assist you throughout this process.