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I-9 Form:  Boulder Campus Employment Eligibility Procedures

 

Introduction

In accordance with the Immigration Reform and Control Act of 1986 ("IRCA"), the University of Colorado at Boulder must verify employment eligibility of employees. Employment eligibility must be documented using the federal Employment Eligibility Verification (I-9) form, and eligibility must be verified for each employee. Please check the following link to the U.S. Citizenship and Immigrations Services website which provides the most current updates to acceptable and unacceptable documents which may not be listed on the I-9. The documents used by the employee to substantiate employment eligibility must be inspected for propriety and authenticity, and an authorized university representative must sign the I-9 form. The IRCA does not apply to employees hired prior to November 6, 1986, who have been continuously on the university's payroll since that date. 

Along with a complete I-9 Form an Affirmation of Legal Work Status Form(pdf) also needs to be submitted.

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The IRCA stipulates that the employment verification process be completed in person, and that verification be completed within three working days of the beginning of employment. Appendix A describes the process used for CU Boulder employees who are hired to work outside of the USA. Penalties for non-compliance can be significant. The procedures described below enable the campus to comply with requirements of IRCA.

 

* E-Verify Program: The University of Colorado is a Federal Contract E-Verify employer, but only employees hired into a position funded by a Federal Contract with the FAR E-Verify clause will be verified in the E-Verify program. In that case, we will provide the Social Security Administration (SSA) and, if necessary the Department of Homeland Security (DHS) with information from each new employee's Form I-9 to confirm work authorization.

For purposes of employment using F-1 STEM OPT employment authorization through Student and Exchange Visitor Program (SEVP) and U.S. Citizenship and Immigration Services (USCIS), however, the University is NOT considered to be an E-Verify employer since not all new University employees are being verified through the E-Verify program.


 

Procedures

Faculty/Staff/Graduate Students

  1. In general, upon acceptance of an offer of employment or within three working days of the beginning of employment, departments must send faculty, staff and graduate student employees to the Department of Human Resources to have employment eligibility verified. Graduate student employees may also have their I-9 verified in the Office of Student Employment. Upon request from a department, the Director of Human Resources may delegate responsibility for verification of employment eligibility. Such departments shall typically have a high level of personnel activity..

     

  2. Only authorized personnel in departments with delegated authority may sign form I-9 on behalf of the university. Individuals with such authority must receive training on form I-9 reporting requirements and identification of falsified identification. The Department of Human Resources will provide such training and maintain a list of employees authorized to approve I-9 forms.

     

  3. I-9 forms completed by departments must be sent to the Department of Human Resources. The Department of Human Resources will review the I-9 forms for completeness and enter the I-9 effective date field in the PeopleSoft Human Resources system. The Department of Human Resources will also complete the I-9 expiration date field, if appropriate.

     

  4. To assist with the collection process, the Department of Human Resources will be available for verification of employment eligibility at events such as orientation sessions for new faculty, graduate students, and employee benefits. In addition, during peak activity periods, a department may request a Department of Human Resources representative be available to verify employment eligibility by calling (303) 492-6893.

Undergraduate Students
  1. The Student Employment area of the Office of Financial Aid located in Regent, Room 205, (303) 492-7349 is responsible for the verification of employment eligibility for the majority of undergraduate student employees. In general, within three days of the start of employment, undergraduate student employees should report to Student Employment to have their employment eligibility verified. Students can also have their I-9 verified in the Department of Human Resources at 3100 Marine Street, Room 373.

     

  2. Upon request by a department, responsibility for verification of employment eligibility for undergraduate students may be delegated, after consultation with the Office of the Assistant Vice Chancellor.  Such departments shall typically have a high level of personnel activity. NOTE: Student Employment will not verify employment eligibility for employees in these departments

     

  3. Only authorized personnel in departments with delegated authority may sign form I-9 on behalf of the university. Individuals with such authority must receive training on form I-9 reporting requirements and identification of falsified identification. The Department of Human Resources will provide such training and maintain a list of employees authorized to approve I-9 forms.

     

  4. I-9 forms completed by the Student Employment or departments with delegated authority must be sent to the Department of Human Resources. The Department of Human Resources will review the I-9 forms for completeness and enter the I-9 effective date field in the PeopleSoft Human Resources system. The Department of Human Resources will also complete the I-9 expiration date field, if appropriate.

 

Compliance 

  1. Campus appointing authorities may not allow employees to work before ensuring that required I-9 documentation will be received within three working days of the beginning of employment.

  2. If employment eligibility is not verified by the third day of employment, employees shall be taken off the work schedule immediately, until documentation is received. The Department of Human Resources, in partnership with Payroll and Benefit Services, reserves the right to temporarily suspend direct deposit of paychecks in an effort to facilitate the completion of I-9 documentation. Continued failure of the employee to submit the required I-9 documentation will result in termination from UCB employment.

     

  3. The Department of Human Resources will produce monthly reports listing active employees whose I-9 effective date field in the PeopleSoft Human Resources system has not been completed, or whose I-9 expiration date has passed. The Department of Human Resources will be responsible for following-up on non-compliance with personnel liaisons and directly with employees as needed.

Departments that fail to comply with this policy shall be responsible for any fines that may be levied against the University.