Happy Friday !
April 1st, 2016 is here and this is no Joke! We now have an expired I-9. The I-9 which was issued in 2013 has officially hit its expiration date of March 31, 2016. Now, what? Have you heard there is a new I-9 with around 9 pages of instructions?
We do have a new I-9, but here is the hitch: we cannot use it because the new form has not yet been activated by USCIS. Here is the memo issued by the folks over at I-9 Central
Until further notice, employers should continue using Form I-9, Employment Eligibility Verification. This current version of the form continues to be effective even after the Office of Management and Budget control number expiration date of March 31, 2016, has passed. USCIS will provide updated information about the new version of Form I-9 as it becomes available.
Employers must complete Form I-9 for all newly hired employees to verify their identity and authorization to work in the U.S. To learn more about Form I-9 visit I-9 Central.
Well, there ya go! So, for now let’s use the expired I-9.
Here is a BEST PRACTICE: Be sure to make a note for yourself and any who come after you that this expired I-9 version is AOK. I would hate to see you or a successor eventually “correcting” I-9s because you see the date completed was after the expiration date. My suggestion is to circle the expiration date and make the note either on the back of the second page or along a top or bottom margin. Initial and date the notation. Train your current HR, Payroll and Management personnel. Perhaps someone will remember 5 years from now when you have moved up and on to your next adventure!
Have a great weekend and… Until Next Time, Be Audit-Secure!