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Form I-9 Examples Related to Temporary COVID-19 Policies

Hey Compliance Warriors!

In this update, USCIS is providing examples of how DHS recommends you notate Form I-9 when remotely inspecting employment authorization and identity documents and then subsequently performing the required physical inspection once normal operations resume. Employers and workplaces that are operating remotely may follow the DHS news release that announced flexibility in requirements related to Form I-9. Read on…

Note:  Examples are provided to assist with Form I-9 documentation you may complete in the future related to remote inspection, physical inspection, or List B policies related to COVID-19. You are not required to update your Forms I-9 based on these examples if there are differences.

How to Notate Remote Inspections and Subsequent Physical Inspections

Figure 1: Completing Section 2 When Inspecting Documents Remotely

Form I-9 Example for remote inspection

Figure 2: Performing Physical Inspection Once Normal Operations Resume

If the person who performed the remote inspection also performs the physical inspection, they should indicate the date they physically examined the documents then add their initials in the Additional Information field.

Form I-9 Example for Performing Physical Inspection Once Normal Operations Resume

Figure 3: Performing Physical Inspection by a Different Person Once Normal Operations Resume

If the person who performed the remote inspection cannot also perform the physical inspection, the person who performs the physical inspection should indicate the date they physically examined the documents as well as their full name and title in the Additional Information field.

Form I-9 Example for Performing Physical Inspection by a Different Person Once Normal Operations Resume

Figure 4: Notating Remote and Physical Inspection for Reverification

Employers should make required notations for remote and subsequent physical inspections of reverifications in the Additional Information field in Section 2. If the same person performs both the remote and subsequent physical inspections for a reverification, complete as shown. If a different person performs the physical inspection, that person should write their full name and title, instead of their initials.

Form I-9 Example for Notating Remote and Physical Inspection for Reverification

How to Notate Extended List B Documents

Figure 5: Entering a List B Document Extended by Issuing Authority in Section 2

Form I-9 Example for Entering a List B Document Extended by Issuing Authority in Section 2

State Document Extension Notice

Employers can confirm that their state has auto-extended the expiration date of state IDs and driver’s licenses by checking the state’s Motor Vehicle Administration or Department of Motor Vehicle’s website.

State Document Extension Notice

Figure 6: Entering an Expired List B Document in Section 2

Form I-9 Example for Entering an Expired List B Document in Section 2

Figure 6b: Updating Section 2 When Employee Presents Unexpired Document Once Normal Operations Resume

If the same person performs both the remote and subsequent physical inspections, complete as shown. Note that if a different person performs the physical inspection, that person should write their full name and title, instead of their initials.

Form I-9 Example for Updating Section 2 When Employee Presents Unexpired Document Once Normal Operations Resume


About LISA SMITH

Lisa Smith is CEO of Andere Corporation and Chief Content Developer at HelpDeskSuites.com. Follow her on Twitter, connect with her on LinkedIn, listen to her Small Business Spoonfuls Podcast, and find more in her Compliance Warriors Facebook Group.

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