Offsite New Hire Employment Verification (I-9) Instructions

The Immigration Reform and Control Act of 1986 requires that all employers verify the identity and work authorization of all individuals, whether U.S. citizens or not, hired after November 6, 1986. Employers comply with this mandate by completing Form I-9 for all newly hired employees. The University of Virginia has an online system for I-9 compliance called I-9 Online. Note: I-9s are not required for newly-hired employees physically performing services outside the U.S.. Departments are required to complete an I-9 should such employees return to the U.S.

Occasionally, departments or schools may hire an employee who will be paid by the University yet will not physically work at the University and, therefore, cannot present original documents to a University representative for inspection. When hiring a person in a remote location to work in a remote (offsite) location (a location other than the University grounds in Charlottesville, Virginia, College at Wise, Wise, Virginia, or other official worksites such as Falls Church, Richmond, Hampton Roads, Roanoke, or Abingdon, Virginia, staffed by University employees) where University employees are not physically present to review original supporting documentation, special procedures are necessary.

Federal law permits the University to seek the services of an authorized representative, such as a notary public or other responsible person, to carry out I-9 responsibilities on behalf of the University. An Authorized Representative can be any competent and willing person who is designated to complete the employee’s Form I-9 on behalf of the University. The designated representative completes the Form I-9 and should follow the same rules for completing the Form I-9 as a University hiring department. In cases involving remote hire and I-9 verification by an authorized representative, the employee and the representative should fill out the paper Form I-9. The department or school will subsequently upload the paper form to the University’s online I-9 system I-9Online. The hiring department and the University itself will be held responsible for the actions of the authorized representative.

Steps

1.Hiring department/school completes the Remote Hire Authorized Representative Notice form.

2.Hiring departments/schools should send the following documents with the employee to the designated Authorized Representative:

a. Completed Remote Hire Authorized Representative Notice form.

b. Remote Hire Authorized Representative Instructions

c. I-9 Form (03/31/2016 expiration date) and I-9 Instructions.

3.The employee should complete Section 1 of the I-9 Form and present to the Authorized Representative along with acceptable documents for review.

4.The Authorized Representative should verify that the employee has completed and signed/dated Section 1 of I-9 Form prior to completing Section 2 on behalf of the University (The employee should NOT use the University’s online I-9 system to complete Section 1). The employee must present to the Representative a suitable set of identification papers as set out in the “List of Acceptable Documents” page of the I-9 Form Instruction. The Authorized Representative may not specify which document(s) from the list they will accept from the employee. The employee may present either:

a. Any one unexpired document from List A, or

b. Two unexpired documents, one from List B (identity) (List B documents MUST have a photo) and one from List C (eligibility).

5.The Authorized Representative should complete Section 2 of I-9 Form (Employer Review and Verification). There are spaces indicating which documents were presented and their associated information. This includes Document Title, Issuing Authority, Document Number, and Expiration Date (if any). Representatives should be aware that only original documents should be accepted for review. Faxes, photocopies, and laminated social security cards are unacceptable. The Authorized Representative should make copies of the employee’s original documents.

6.The Authorized Representative should also complete the Certification part of Section 2 of I-9 Form. The employment begin date should be provided to the Authorized Representative on the Remote Hire Authorized Representative Notice Form. The Section 2 Certification should be completed as follows:

a. Enter the employee’s date of hire (see remote Hire Authorized Representative Notice Form).

b. Sign the Authorized Representative section.

c. Indicate the University Of Virginia name and address in the Business or Organization name section.

d. Date the form (enter the date on which you reviewed the employee’s documents).

e. If a notary, place the notary seal on the Remote Hire Authorized Representative Notice Form. Do not put a notary seal on the I-9 form itself.

7.The Authorized Representative returns the completed Form I-9, along with copies of the employee’s documents, to the hiring school or department’s I-9 Specialist.

8.The I-9 Specialist will upload the I-9 form with the appropriate documents into the I-9Online system.

Hiring departments, I-9 Specialists, employees, or Authorized Agents should contact Human Resources-Compliance and Immigration Services with any questions at (434) 924-4393 or email Christine Langford crf6b@virginia.edu.