Marietta Hendricks, the Human Resources Manager for a local manufacturer, shared her insights and experiences from a recent I-9 audit by the Department of Homeland Security (DHS) at the January meeting of the Kane DuPage Human Resources Association.
Here are some of the most salient points from Marietta’s presentation on striving toward full I-9 compliance.
- The local manufacturer surprised by this DHS audit is a relatively small employer with no other geographic locations. Earlier this week, I spoke with the Vice President of Administration for another manufacturer with only a local facility who had also been audited by DHS in 2014. So it’s not only the large, multi-location employers who are being held accountable for I-9 compliance.
- When the DHS agents appeared at the facility, they asked to receive the I-9 documents immediately. Marietta asked for some additional time because she wanted to contact their business counsel and wanted to have time to photocopy the originals she would be turning over to DHS. She was given a week.
- Marietta shared her understanding that an employer could conduct their own internal audit of I-9 documents and processes. If you choose to do that, she said that missing information should be added in a different color pen and initialed/dated.
- She also noted that the one blank she consistently missed on the current I-9 form is at the very top of the page on the employer side of the form. This is the blank where you should print the name of the new employee who completed the other side of the form. DHS cited this in their report, but Marietta’s employer wasn’t fined for this omission.
- DHS did find that the ID presented by a few employees was questionable. However, the HR Department had done its due diligence in thoroughly recording the ID details. DHS accepted HR’s decision that the documents seemed authentic (in terms of employer accountability for compliance). For the employees whose ID were challenged, Homeland Security agents returned for individual meetings with each of those employees. As the HR representative for the employer, Marietta was allowed to attend those meetings.
Also a hearty thank-you to the staff of Szechwan Restaurant in downtown St. Charles, providing our meeting room and tasty buffet luncheon.
Contact our staff for additional resources about I-9 compliance and other human resource challenges.
by Elyse Williamson