Human Resources

Are seasonal workers considered rehires when the seasonal worker has every expectation to return to the job the following season, such as from one holiday season to another? Must the employee complete a new Form I-9 each season?

The regulations provide that if the individual is continuing in his or her employment, such as may be the case with seasonal employment, and has a reasonable expectation of employment at all times, his or her return to work would not be considered a new hire, so a new Form I-9 is not required. Employers should continue to maintain and store the completed Form I-9 as if there was no interruption in employment. Therefore, the employer should conduct any reverification of employment authorization as necessary.

If the employer determines that the employee was terminated and is now rehired, and the rehire occurs within three years from the date the previous Form I-9 was completed, the employer may complete a new Form I-9 or rely on the previously completed Form I-9. For additional information on continuing employment, refer to the M-274 Part Two, Completing Section 3.


April 2017

Tags: I9