From: Noreen Montgomery, Senior Director Employment & Staffing
As a follow-up to our previous communication in August regarding the return to the normal Form I-9 process effective Sept. 1, 2021, the following is additional clarification on the LawLogix document capture feature and the Department of Homeland Security’s virtual verification process.
|
Purpose |
When is it available? |
|
|
LawLogix Document Capture Feature |
This LawLogix feature gives the employee the option to upload a copy of their identity and employment eligibility document(s) that they plan to present in-person prior to the I-9 preparer completing Section 2 of the Form I-9. This feature does not replace the in-person inspection of the identity and employment eligibility document(s). |
Ongoing |
|
DHS Virtual Verification (Temporary Exception for Employers Operating Remotely) |
On March 20, 2020, the Department of Homeland Security (DHS) issued guidance during the COVID-19 pandemic, which allows employers operating remotely to temporarily defer in-person physical inspection of identity and employment eligibility document(s) for completion of the Form I-9. While the employer is operating remotely, the employer can verify supporting document(s) virtually to complete Section 2 and then verify the original document(s) in-person once normal operations resume or the guidance is terminated, whichever is earlier. |
March 20, 2020 – August 31, 2021* *This temporary exception no longer applies to UNC-Chapel Hill as normal operations have resumed. |
As a reminder, the virtual verification process ended on August 31, 2021, following the University’s return to normal operations. Thank you for working so diligently to complete in-person physical inspections of document(s) for Forms I-9 completed using virtual verification.
Effective Sept. 1, 2021, campus I-9 preparers must follow the normal I-9 process, which includes physically examining original identity and employment eligibility document(s) presented by the employee and completing Section 2 within three business days of the date of hire.
If the employee chooses to use LawLogix’s document capture feature after they complete Section 1, the I-9 preparer must verify that the original document(s) presented in-person match those uploaded by the employee and complete Section 2. Conversely, if the employee chooses not to upload their supporting document(s) or presents different document(s) in-person, the I-9 preparer must scan and upload a copy of the document(s) prior to completing Section 2.
Questions?
If you should have any questions regarding this guidance, please contact Rachel Cameron, I-9 Compliance Supervisor, at (919) 843-8544 or rachel_cameron@unc.edu.
For general Form I-9 information and resources, refer to the Form I-9 Information for Departments webpage. For general Form I-9 guidance and assistance, please contact the OHR I-9 unit at (919) 962-0985 or eevquestions@listserv.unc.edu.
Thank you for continuing to partner with the OHR I-9 Unit to ensure continued Form I-9 compliance.