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To: HR Officers and Secondary Contacts
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.


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).


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.


If you should have any questions regarding this guidance, please contact Rachel Cameron, I-9 Compliance Supervisor, at (919) 843-8544 or

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

Thank you for continuing to partner with the OHR I-9 Unit to ensure continued Form I-9 compliance.

Categories: HRO
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