In light of recent guidance issued related to recent events, U.S. Citizenship and Immigration Services continues to indicate to employers that each document presented for completion of the Form I-9 must be physically examined, with the employee being physically present, to determine if it reasonably appears to be genuine and relates to the employee presenting it. Reviewing or examining documents via webcam is not permissible.
Departments must make every effort to complete Section 1 on or before the date of hire and Section 2 of the Form I-9 in-person with the employee within three business days of the date of hire.
However, if the employee and/or campus I-9 preparer cannot meet in person, please refer to the following guidance for further instructions.
SHRA, EHRA Non-Faculty & Faculty Attending NEO In-Person
For employees who attend the in-person Welcome to Carolina Blue New Employee Orientation (NEO), the OHR I-9 unit will meet with the employee to review/accept supporting documents and complete Section 2 during the session.
The OHR I-9 unit will work with the employee if they present incomplete supporting documents during the sessions and/or follow-up is needed.
SHRA, EHRA Non-Faculty & Faculty Attending NEO via Zoom
For employees who participate in the Welcome to Carolina Blue NEO session via Zoom, the following steps must be taken:
- Talent Acquisition Partner/OHR I-9 unit – Sends the employee an invitation to complete Section 1 on or before the date of hire via LawLogix.
- Campus I-9 preparer – Reviews/accepts supporting documents and completes Section 2 as soon as the employee can meet in person. Campus I-9 preparers must monitor employees who do not have a complete Form I-9 in the Top Pending I-9s panel on the LawLogix dashboard.
- Campus I-9 preparer – Before marking the I-9 approved, the campus I-9 preparer includes the following case note with the employee’s Form I-9: Due to the global impact of COVID-19 and U.S. national emergency, Section 2 was completed as soon as practicable.
Important – The employee will be allowed to work pending completion of their Form I-9.
Remote Hires (Employees Working More Than 35 Miles from Campus)
For remote hires, the following steps must be taken:
- Campus I-9 preparer – Submits a Remote Hire Request at least two weeks prior to the employee’s anticipated hire date. Refer to the Remote Hire section in the university compliance manual and desk reference for more information.
- OHR I-9 unit – Makes every effort to coordinate a remote agent to complete the Form I-9 as soon as possible. The OHR I-9 Specialist includes the following case note with the employee’s Form I-9: Due to the global impact of COVID-19 and U.S. national emergency, Section 2 was completed as soon as practicable.
Important – The employee will be allowed to work pending completion of their Form I-9.
All Other New Employees (Direct-Hire Temp, Postdocs and Faculty Not Attending NEO)
For all other employees including direct-hire temporary employees and Faculty who do not attend the Welcome to Carolina Blue new employee orientation session, the following steps must be taken:
- Campus I-9 preparer – Sends the employee an invitation to complete Section 1 on or before the date of hire via LawLogix. Refer to Part 2, Option A in the desk reference for more information about how to send an I-9 invitation.
- Campus I-9 preparer – Reviews/accepts supporting documents and completes Section 2 as soon as the employee can meet in person. Campus I-9 preparers must monitor employees who do not have a complete Form I-9 in the Top Pending I-9s panel on the LawLogix dashboard.
- Campus I-9 preparer – Before marking the I-9 approved, the campus I-9 preparer includes the following case note with the employee’s Form I-9: Due to the global impact of COVID-19 and U.S. national emergency, Section 2 was completed as soon as practicable.
Important – The employee will be allowed to work pending completion of their Form I-9.
Questions?
For general Form I-9 information and resources, refer to the Form I-9 Information for Departments webpage.
If you should have any questions about the I-9 process during the coronavirus (COVID-19) outbreak, please contact the OHR I-9 unit at (919) 962-0985 or eevquestions@listserv.unc.edu.