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To: HR Officers and Secondary Contacts
From: Noreen Montgomery, Senior Director Employment & Staffing
Re: Final Reminder- Important Changes to Form I-9 Process Effective September 1, 2021


As we previously communicated on August 11, as a result of the University’s return to normal operations on July 19, the interim Form I-9 guidance issued by the Department of Homeland Security no longer applies. Accordingly, interim Form I-9 procedures will end on August 31, and normal Form I-9 procedures will resume effective September 1, 2021.

Schools and divisions are responsible for enforcing compliance with the following guidance by resuming the normal I-9 process effective September 1, 2021, and ensuring the physical inspection of I-9 supporting documentation is completed for all outstanding Forms I-9 by September 3, 2021.

Outstanding Forms I-9 Completed prior to August 31, 2021

In accordance with the Department of Homeland Security’s interim guidance, the campus I-9 preparer must do the following for all Forms I-9 that were completed via virtual verification and still need physical inspection within three business days of August 31, which is no later than September 3, 2021:

  1. Review the Top I-9s Needing Further Action on the LawLogix dashboard panel to identify the Forms I-9s that require in-person verification if the reason field indicates “Physical Inspection.”
  2. Schedule a time to meet with each employee to physically inspect their original identification and work authorization document(s).
  3. Verify the original identification and work authorization document(s) presented to the documents on the OnDocs tab. If the employee chooses to present different document(s), review the document(s) presented, scan, upload, and replace the document(s) on the OnDocs tab in LawLogix.
  4. Amend Section 2 by entering the physical inspection information on the I-9 via the “Enter Inspection Information” button on the I-9 Details tab and following the LawLogix prompts.
  5. Click the “Approve Changes” button to approve the Amendment indicating physical inspection on the I-9 Details tab.
  6. Uncheck the COVID-19 “Virtual Verification Exception” box on the Details tab. Click the “Update Info” button to save.

Forms I-9 Completed on or after September 1, 2021

New Hires and Hires
For employees hired on or after September 1, 2021, the campus I-9 preparer must complete the Form I-9 via the normal Form I-9 process as outlined in the below steps:

  1. Send the employee the email invitation to complete Section 1 via LawLogix once the job offer has been accepted and prior to the effective date of hire. Note: The employee must complete Section 1 of the Form I-9 on or before the employee’s date of hire.
  2. Schedule a time to meet with the employee in-person to physically inspect their original identity and employment authorization document(s) within three business days of the date of hire. Note: The virtual verification option can no longer be used after August 31, 2021.
  3. If the employee uploaded a copy of their identification and work authorization document(s) when they completed Section 1 using LawLogix’ document capture feature, physically inspect the original document(s) presented and compare them to the documents on the OnDocs tab. Note: OneDrive can no longer be used to obtain Form I-9 supporting document(s) from employees after August 31, 2021.
  4. If the employee did not upload a copy of their document(s), physically inspect the original document(s), scan, and upload a copy of the document(s) on the OnDocs tab in LawLogix.
  5. Once you have physically inspected the original document(s), complete Section 2 of the Form I-9 within three business days of the employee’s date of hire. Note: Section 2 cannot be completed before the physical inspection of documents occurs. In addition, the same person that completes and certifies Section 2 must be the person who physically meets with the employee and reviews their I-9 documentation.

Reverifications
For employees with an expiring temporary employment authorization, the campus I-9 preparer must do the following:

  1. Meet with the employee in-person to physically inspect the original identity and employment authorization document(s).
  2. Upload the identity and work authorization document(s) on the OnDocs tab in LawLogix.
  3. Complete Section 3 of the Form I-9 on or before the expiration of the current employment authorization. Note: The same person that completes Section 3 must be the person who physically meets with the employee and reviews their reverification documentation.

Remote Hires
The remote Form I-9 process is available for employees who are working more than 35 miles or more from UNC-Chapel Hill.

If a remote I-9 request is needed, hiring departments must submit the request at least two weeks prior to the employee’s anticipated date of hire to ensure sufficient time to complete the I-9 process.

For more information on the remote hire Form I-9 process, please visit the Form I-9 Information for Departments webpage and review the Remote Hires section of the I-9 & E-Verify Compliance Manual.

Questions?

For general Form I-9 information and resources, refer to the Form I-9 Information for Departments webpage. For general Form I-9 questions, please contact the OHR I-9 unit at (919) 962-0985 or eevquestions@listserv.unc.edu.

If you should have any questions regarding these changes to the Form I-9 process, please contact Rachel Cameron, I-9 Compliance Supervisor at (919) 843-8544 or rachel_cameron@unc.edu.

 
 

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